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The sole issue before the Court was whether the transactions resulted in “abusive tax avoidance” within the meaning of subsection 245(4) of the Act. [5]              I have concluded that the transactions undertaken in this case circumvented the application of the anti-avoidance rule in section 212.1 in a manner that “frustrated or defeated the object, spirit or purpose” of section 212.1 in general and subsection 212.1(4) in particular: Canada Trustco Mortgage Company v Canada, 2005 SCC 54 at paragraph 45. ... (emphasis added) (Angelo Nikolakakis and Alain Léonard, “ The Acquisition of Canadian Corporations by Non-Residents: Canadian Income Tax Considerations Affecting Acquisition Strategies and Structure, Financial Issues, and Repatriation of Profits ” Report of Proceedings of Fifty-Seventh Tax Conference, 2005 Conference Report (Toronto: Canadian Tax Foundation, 2006), 21:1-45.) ...   $ ACB/FMV = $889,413,400 PUC=$911,729     UCL                                                         iii.             ...

Szymczyk] of his statutory obligation to pay ” (at para. 108 and 118). [12]         GMCL and Mr. ... It is sufficient for purposes of these reasons to refer to the brief description of the two branches provided in Ryan v Moore, 2005 SCC 38: 4                 Estoppel by convention operates where the parties have agreed that certain facts are deemed to be true and to form the basis of the transaction into which they are about to enter (G.H.L. ... Pentney Deputy Attorney General of Canada Ottawa, Ontario     ...

CITATION: 2017 TCC 25   COURT FILE NO.: 2015-1199(EI)   STYLE OF CAUSE: CHANTAL CYR v. M.N.R.   PLACE OF HEARING: Montreal, Quebec   DATE OF HEARING: October 20, 2016   REASONS FOR JUDGMENT BY: The Honourable Justice Gaston Jorré   DATE OF JUDGMENT: February 13, 2017   APPEARANCES:   For the Appellant: The Appellant herself Counsel for the Respondent: Amelia Fink COUNSEL OF RECORD:     For the Appellant:       Firm:     For the Respondent: William F. ... In this respect it is worth recalling that a person can simultaneously be an employee of one person while also providing services to other persons who are clients. [33] In doing so, it is assigning the work. [34] In this case the chance of profit or risk of loss is clearly the most important factor. [35] 2005 TCC 338. [36] 2007 TCC 653. [37] The decision came relatively soon after the decision of the Federal Court of Appeal in Royal Winnipeg Ballet v. ...

As such, they are zero-rated supplies. [3]   There is a complicating factor. ... Supply … [the provision of] … property or services in any manner including sale, transfer, barter, exchange, license, rental, lease, gift or disposition. ... Bocock DATE OF JUDGMENT: May 29, 2018   APPEARANCES:   Counsel for the Appellant: Al Meghji Al-Nawaz Nanji Counsel for the Respondent: Justine Malone   COUNSEL OF RECORD: For the Appellant: Name: Al Meghji Al-Nawaz Nanji   Firm: Osler, Hoskin & Harcourt LLP For the Respondent: Nathalie G. ...

Masse" Deputy Judge Masse   Citation: 2022 TCC 20 Date: 20220216 Docket: 2020-1441(IT)I BETWEEN: SERGE FYFE, Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... Watts, 2005 TCC 651 So, although documentation is very important, the lack of documentation is not necessarily decisive. ... Huet, his main customer, with respect to the most important issue — the existence of a business. ...

The Appellant had sought to obtain a decision that provided it was carrying on business in Bermuda via its Bermuda branch, SLAC, in both 2006 and 2007 and that subsection 138(11.3) of the Income Tax Act (the “ Act ”) first applied to its 2006 year, effectively arguing it did not have to carry on business in Bermuda in 2005 as a precondition to the applicability of that provision in 2006. [9]              The Judgment clearly found that the Appellant was not carrying on business in Bermuda in either of 2006 nor 2007 and that in effect the earliest the Appellant would be able to avail itself of the provisions of subsection 138(11.3) was in 2009. ... Pizzitelli DATE OF COSTS JUDGMENT: June 5, 2015 APPEARANCES: Counsel for the Appellant: Hemant Tilak Pooja Samtani Al Meghji Alexander Cobb Victoria Creighton Counsel for the Respondent: Naomi Goldstein Stephen Oakey Jenna Clark   For the Respondent:     William F. Pentney Deputy Attorney General of Canada Ottawa, Canada     ...

THE QUEEN   REASONS FOR JUDGMENT BY: The Honourable Justice Gaston Jorré   DATE OF JUDGMENT: October 20, 2017     APPEARANCES:     Counsel for the Appellant: Maurice P. Chiasson, Q.C.   Counsel for the Respondent: Jan Jensen COUNSEL OF RECORD:     For the Appellant: Maurice P. ... That Act was enacted on April 25, 1849. [36] 2005 SCC 54. [37] Further, the technical notes set out that this change was put into place to remedy a problem with valuing buildings receiving government funding for individuals having special needs or limited financial resources. ...

II.   Background [3]   The Canadian Armed Forces include a regular force and a reserve force. ... IV.   Analysis A.   Preliminary Matter [19]   I note from reviewing Mr. ... Put otherwise, the interpretation of a statutory provision must be conducted according to a textual, contextual, and purposive analysis to find meaning that is harmonious with the statute as a whole (see Canada Trustco Mortgage Co v Canada, 2005 SCC 54 at para 10). [45]   Mr. ...

Basis for Striking out Further Amended Reply [17]   As established in the following cases, the test for striking out a pleading is difficult to meet and the threshold to strike is high: ·   in Hunt v. ... Where a reasonable prospect of success exists, the matter should be allowed to proceed to trial.”; ·   in French v. ... Drouin Deputy Attorney General of Canada Ottawa, Canada     ...

(McLachlin C.J. and LeBel, Deschamps, Fish, Cromwell, Moldaver and Karakatsanis JJ. concurring)   Abella J.         ... Nutravite Pharmaceuticals Inc., 2005 FCA 269, 339 N.R. 56; Molson Breweries v. ... Nutravite Pharmaceuticals Inc., 2005 FCA 269, 339 N.R. 56.  [71]                           Notwithstanding this shared jurisdiction, the Trade-marks Opposition Board’s decisions are nevertheless reviewed on a reasonableness standard, as Rothstein J.A. concluded for the majority in Molson Breweries v. ...