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The appeals process was added to the legislative scheme effective for notices of intention to revoke issued after June 12, 2005. ... NEAR J.A.   DATED: january 30, 2019   APPEARANCES: E. Blake Bromley Josh Vander Vies   For The Appellant   Lynn M. ... Drouin Deputy Attorney General of Canada   For The Respondent     ...

The submissions are not to exceed 10 pages.   Signed at Ottawa, Canada, this 27th day of January 2022. ... The bulletin states that the situations or circumstances that may engage subsection 84(2) could include the following: • the funds or property of the transferred corporation are quickly distributed to the estate after the death of the taxpayer; • the shares of the transferred corporation are liquid shares, and the corporation is not engaged in any activity or business. [30] Are the conditions described by the auditor cumulative? ... Hogan DATE OF AMENDED JUDGMENT: January 27, 2022 APPEARANCES: Counsel for the Appellant: Martin Delisle Lisa-Marie Gauthier   Counsel for the respondent: Anne Poirier COUNSEL OF RECORD: For the appellant: Name: Martin Delisle Lisa-Marie Gauthier   Firm: De Grandpré Chait For the respondent: François Daigle Deputy Attorney General of Canada Ottawa, Canada     [1] 2013 FCA 110 (MacDonald). [2] Ibid., paragraph 17. [3] Ibid., paragraph 28. [4] 2021 SCC 49. [5] Ibid., paragraph 1. [6] 2005 SCC 54, [2005] 2 S.C.R. 601. [7] Ibid., paragraph 12. [8] [1942] S.C.R. 269 (Merritt). [9] [1970] S.C.R. 64 (Smythe). [10] [1999] 3 S.C.R. 622. [11] Ibid., paragraph 39. [12] According to the intent of Parliament, there has to be a complete "rollover" at the time of the winding-up. [13] Subsection 104(24) of the Act. [14] Brown v. ...

Polubiec failed to report the following amounts of investment income:   Year   Dividends   Interest Other Income   Miscellaneous s.163(1)(a) Amount             2007 $6,253 $73 $12,317 $630 [6] $12,316 2008 $6,814 $380 $16,447   $23,641 2009 $16,392 $534 $11,394   n/a 2010 $10,935   $8,876 $83 [7] $13,149 2011 $29,159     $122 [8] $20,516 [8]   Mr. ... Polubiec must have failed to report income in one of the three taxation years preceding 2007 (i.e., 2004, 2005 or 2006), otherwise the condition set out in paragraph 163(1)(b) of the ITA would have not have been satisfied for 2007, such that it would not have been possible for the CRA to have assessed a penalty for that year. [10]   Mr. ... See also Knight, supra note 5, ¶2-3, 25 & 30. [61]   Knight, supra note 5, ¶8. [62]   Chan, supra note 46, ¶15. [63]   Norlock, supra note 15, ¶15. [64]   Corporation de l’école polytechnique v The Queen, 2004 FCA 127, ¶29 & 32-38. ...

J.         Signed in Ottawa, on March 20 th, 2009.         IN THE TAX COURT 2007-2665(IT)G 2007-2667(IT)G 2007-2669(IT)G BETWEEN: NIELSEN DEVELOPMENT CO. ... I ask for the court to be adjourned.   (PROCEEDINGS CONCLUDED AT 2:21 P.M.)       ... Beaton       COURT REPORTER         ...

Coastridge was dissolved in September 2005 and restarted in April 2006. [6]   In 2006, Coastridge purchased Tomoya Japenese Restaurant (“Tomoya”), a restaurant which operated in Burnaby, British Columbia. ... MacPhee” MacPhee J   Appendix “A”                             CITATION: 2020 TCC 72 COURT FILE NO.: 2016-4824(IT)G; 2016-4826(IT)G;   2015-5443(GST)G STYLE OF CAUSE: STUART XUE AND HER MAJESTY THE QUEEN and STEPHANIE XUE AND HER MAJESTY THE QUEEN and   COASTRIDGE ENTERPRISES LTD. ... Douvelos   Counsel for the Respondent:   R.D.F. Wilhelm   R. Whittaker   COUNSEL OF RECORD:   For the Appellant:     Name:     Firm:   Fore the Respondent:   Nathalie G. ...

If the customer returns the vehicle to a GM dealership, GMAC quickly sells the vehicle. [2]              This appeal involves three different issues: (a)        Excess Kilometre Charges: In its taxation periods ending December 31, 2005, November 30, 2006, December 31, 2006 and December 31, 2007, GMAC charged certain customers additional charges for driving more kilometres than their leases permitted (“Excess Kilometre Charges”). ... Pentney Deputy Attorney General of Canada Ottawa, Canada     [1]           This formula was not entered into evidence. ... Simard-Beaudry Inc., 1971 CarswellNat 239 (FCTD);   R. v. Riendeau ¸ 91 DTC 5416 (FCA);  and subsection 152(3) [13]          1984 CarswellNat 1653 [14]          Burns, at para 2 ...

M.N.R., 2005 TCC 291 and argued that that case stands for the proposition that the main issue is whether or not the Minister's decision was reasonable under all of those circumstances. [64]     In the case at bar, the questionnaires on behalf of the Payor and the employee were signed by the Appellant. [65]     In Forget v. ... CITATION:                                        2006TCC409 COURT FILE NOS.:                          2005-2663(EI) and 2005-2664(CPP) STYLE OF CAUSE:                           NELSON OATES AND M.N.R. ... Wight Agent for the Intervener Seandelle Pike COUNSEL OF RECORD:        For the Appellant:                    Name:                                                 Firm:        For the Respondent:                     John H. ...

II.   Decision under review [21]   The Decision is dated September 25, 2018. ... Additionally many posts appear as recruitment initiatives for the Islamic State […] […] [170] […] There is no doubt that Mr. ... R. v THE MINISTER OF PUBLIC SAFETY AND EMERGENCY PREPAREDNESS   PLACE OF HEARING: Toronto, Ontario   DATE OF HEARING: April 24, 2019   JUDGMENT AND REASONS: WALKER J.   ...

I heard testimony from three witnesses: Mark Torrance, the National Director of Estate Wineries for the Appellant; Thierry Clement, a server with over 40 years of experience working in restaurants, who worked for the Appellant at the Peller Estates Winery Restaurant from 2005 to 2009; and Jennifer Dearborn, a server who worked at Peller Estates Winery Restaurant from May, 2002 to November 22, 2014, when her employment was terminated by the Appellant. ... Similarly, the Appellant paid CPP and EI on the function tip because “… we were guaranteeing this amount … as income they could rely upon …” (Transcript, March 26, 2015, at page 127). ... Pentney Deputy Attorney General of Canada Ottawa, Canada     ...

Eyeball sets off the 398 Note against, and in payment of, the Eyeball Note   payable by Eyeball, and the 398 Note is canceled and 398 is released from all liability thereunder. 2. 398 sets off the Eyeball Note against, and in payment of, the 398 Note payable by 398, and the Eyeball Note is canceled and Eyeball is released from all liability thereunder. [14]   For illustrative purposes, the before and after corporate landscape in chart form may be contrasted as follows: Figure 1 – Before share for property exchange;                 Figure 2 – Upon execution of the ATA; Figure 3 – After set-off/Mutual Debt Cancellation Agreement;   Figure 4 – Upon Escrow Release;   [15]   Lastly the parties entered into an escrow agreement (“Escrow Agreement”) under which various documents were placed into escrow for a short number of days. ... The relevant effective provisions of that agreement provided:   [….] 1. ... A person who was under 18 years of age at the time of transfer;     or,   iii. ...