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Three years later, that same accountant recommended that the appellants restore the “ status quo ante ”, which they attempted to do. ... Canada, 2005 FCA 329, the Court stated that “the benefit must be real”, and the shareholder cannot be taxed on the basis of a “legal fiction” (at paragraphs 27 and 28). [89] The appellants also referred to Canada (Attorney General) v. ... Smith DATE OF JUDGMENT: November 28, 2022 APPEARANCES: Counsel for the Appellants: Julie Gaudreault-Martel Nicole Platanitis   Counsel for the Respondent: Christian Lemay Karman Kong COUNSEL OF RECORD: For the Appellants: Names: Julie Gaudreault-Martel Nicole Platanitis   Firm: BCF LLP   For the Respondent: François Daigle Deputy Attorney General of Canada Ottawa, Canada     ...

Kaur agreed to an Interim Without Prejudice Consent Parenting Order (the “ Interim Consent Parenting Order”). ... Spiro DATE OF JUDGMENT: June 17, 2025 APPEARANCES:   For the Appellant: The Appellant herself Counsel for the Respondent: Ramneek Kaur Sidhu   COUNSEL OF RECORD: For the Appellant: Name: n/a   Firm: n/a For the Respondent: Shalene Curtis-Micallef Deputy Attorney General of Canada Ottawa, Canada   [1] Ms. ... See also Picard v The Queen, 2005 TCC 509 at para 15. ...

Hamel signed the Death of an RRSP Annuitant – Refund of Premiums form to designate $69,758 of that RRSP as a refund of premiums for the 2017 taxation year (Exhibit G of Mr. ... Canada (Attorney General), 2005 FCA 404 ”. [63] In Canada (Minister of Citizenship and Immigration) v Vavilov, 2019 SCC 65 [Vavilov], the Supreme Court did not address the standard applicable to alleged breaches of procedural fairness, except to reiterate the factors set out in Baker v Canada (Minister of Citizenship and Immigration), [1999] 2 S.C.R. 817 at paragraph 77. ... A Reasonable Decision Is One That Is Both Based on an Internally Coherent Reasoning and Justified in Light of the Legal and Factual Constraints That Bear on the Decision ”, then under “(2) A Reasonable Decision Is Justified in Light of the Legal and Factual Constraints That Bear on the Decision”, and finally under “(e) Submissions of the Parties ”. ...

OVERVIEW [1]   These reasons are in respect of a costs award regarding the decision of MacDonald v The Queen, 2017   TCC   157, [2017]   TCJ   No   121 (QL), which I   have decided wholly in favour of the Appellant, with costs, by judgment dated August   8,   2017, (the   “Judgment”). ... The sole issue at trial was whether cash settlement payments in the amount of $9,956,837 made by the Appellant during the 2004, 2005 and 2006 taxation years in partial and final settlement of a forward contract were on account of income and resulted in business losses or whether those payments were on account of capital and resulted in capital losses. ... The objectives of an award of costs are compensation and contribution, and not punishment (Mariano et al v The Queen, 2016   TCC   161 at paras   23 and 27, 2016   DTC   1146). [45]   As explained by Justice   Boyle in Martin v The Queen, 2014   TCC   50, 2014   DTC   1072 (para   14): 14  . . .  ...

Webb” Webb J.       Citation: 2009TCC357 Date: 20090706 Docket: 2007-623(IT)G BETWEEN: ANWAR SARWARI, Appellant, and   HER MAJESTY THE QUEEN, Respondent.     ... It's not taxable.         Q.     Is that reflected in the net worth?         ... R., [2005] 4 C.T.C. 2341 (T.C.C. [General Procedure]), Justice Rip dealt with the issue and concluded that the Crown must satisfy the onus necessary to impose gross negligence penalties despite finding that the unreported amounts were to be included in the taxpayer's income. ...

Level 5-            Corporate System             Level 4-            Business Support             Level 3-            Process Management             Level 2-            Process Control             Level 1-            Real Time Control             Level 0-            Sensors and Activators The plan identifies and maps the extent of integration between each level. ... Cooper's analysis using the various methods is as follows:           Lines of code                 -         $47,000,000 (NZ)           Development time            -        $41,100,00 (NZ)           Backfire conversion         -         $52,000,000 (NZ) [45]     Mr. ... Accordingly, MACC has assumed that the fair market value of the Software will decline at an average annual compound rate of approximately 11% from 1993 through 2002, but then at an average annual compound rate of approximately 40% from 2002 through the end of 2005. [54]     I agree. ...

It still argues that if there were inattention, the mention of " inattention of the income tax return preparer " in Mr. ... " Réal Favreau " Favreau J. Translation certified true on this 18th day of November 2020. ... Drouin Deputy Attorney General of Canada Ottawa, Canada   ...

Canada Border Services Agency, 2010 FC 1261   Federal Court   Cour fédérale             Date: 20101209 Docket: T-1597-09 Citation: 2010 FC 1261 Ottawa, Ontario, December 9, 2010 PRESENT:     The Honourable Mr. Justice Shore     BETWEEN:   TRE MAIALI FASHION GROUP INC.       Applicant   and       The president of the Canada border services agency AND THE MINISTER OF NATIONAL REVENUE       Respondents              REASONS FOR JUDGMENT AND JUDGMENT   I.  ... Stephen Rigby, issued an Authorization to Exercise the Powers or Perform the Duties and Functions of the Minister of Public Safety and Emergency Preparedness under the Customs Act (Authorization), pursuant to subsection 2(4) of the Customs Act and subsection 12(1) and (2) of the Canada Border Services Agency Act, 2005, c. 38. ...

Signed at Ottawa, Canada, this 5th day of December 2007.     "François Angers" Angers J.       ... Signed at Ottawa, Canada, this 5th day of December 2007.       "François Angers" Angers J.       ... The Queen, 2005 TCC 666, at paragraphs 40, 41 and 42.   [40]      In Backman v. ...

Pizzitelli” Pizzitelli J.   Docket: 2018-1955(IT)G BETWEEN: JEREMY FREEDMAN, Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... Canada, 2005 FCA 386 at paragraph 8, citing Justice Cattanach of the Federal Court: 8. ... Rebecca Potter   Firm: Thorsteinssons LLP For the Respondent: François Daigle Deputy Attorney General of Canada Ottawa, Canada   ...