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The amounts of the ITCs that are supportable by those Invoices are tabulated as follows: Table 7     Supplier Invoice Date   Fee Total HST Commercial Portion     ITC Mark 31 Dec ’13   $42,000 $5,460 75% $4,095.00 Deborah 31 Dec ’13   24,000 3,120 25% 780.00 Lanmark 31 Dec ’13 53,000 57,000 6,890 7,410 75% 100% 5,167.50 7,410.00   Mark 6 May ’14   50,000 6,500 75% 4,875.00 Deborah 6 May ’14   24,000 3,120 25% 780.00 Mark 31 Mar ’15   50,000 6,500 75% 4,875.00 Deborah 31 Mar ’15 24,000 3,120 25% 780.00             Lanmark 31 Mar ’15     53,000 30,000 6,890 3,900 75% 100% 5,167.50   3,900.00 Total         $37,830.00 [77]   Accordingly, 137ON is entitled, during the reporting periods in question, to ITCs in the aggregate amount of $37,830. ... APPENDIX A Information Prescribed by Section 3 of the ITCI Regulations     3(a)(i) 3(a)(ii) 3(a)(iv) 3(b)(i) 3(b)(iii) 3(c)(ii) 3(c)(iii) 3(c)(iv)     Invoice Name of Supplier Invoice Date Amount Payable Supplier’s GST Number Amount of HST Name of Recipient Terms of Payment   Description of Services s.169(4) Compliant Mark 2013   Yes Yes Yes No* Yes Yes Yes Yes Yes Deborah 2013   Yes Yes Yes No* Yes Yes Yes Yes Yes Cole 2013   Yes No Yes No Yes Yes Yes Yes No Lanmark 2013   Yes Yes Yes No* Yes Yes Yes Yes Yes Mark 2014   Yes Yes Yes Yes Yes Yes Yes Yes Yes Deborah 2014   Yes Yes Yes Yes Yes Yes Yes Yes Yes Lanmark 2014   Yes Yes Yes No* Yes Yes Yes No No Mark 2015   Yes Yes Yes Yes Yes Yes Yes Yes Yes Deborah 2015   Yes Yes Yes Yes Yes Yes Yes Yes Yes Lanmark 2015   Yes Yes Yes Yes Yes Yes Yes Yes Yes   * The respective GST registration numbers are shown on other Invoices.         ... See also Doiron v Haché, 2005 NBCA 75, ¶57; and New Brunswick v Stephen Moffett Ltd., 2008 NBCA 9, ¶10. [68]   Sydney Mines, supra note 65, ¶17. [69]   Ibid., ¶21. [70]   Myrdan Investments, supra note 64, ¶27; and Sydney Mines, supra note 65, ¶22. [71]   This determination is not to be taken as a suggestion that, in other cases, counsel should not take reasonable care when drafting a list of documents or compiling a book of documents. ...

The investment:          a)       The product is a completed 97 suite luxury condominium located in Dallas, Texas.          ... e)       Suggested amounts for the Young/Duncan Group:                   1) Cash investment of $720,000.                   2) Tax loss allocation approximately $6 million.                   3) Ownership: Approximately 15%. 5.       ... The results are the following: Eric Noble December 5, 2005 Page 9 of 11 Analysis of Cash Flow Model 1- Scenario 1 4.5 Percent Annual Price Increase- Without CMF Fee Analysis of Cash Flow Model 1- Scenario 2 4.5 Percent Annual Price Increase- With CMF Fee Investor Purchase Price                                                $1,342,000 Investor Purchase Price                                             $2,600,000 Net Cash Flow                                                             $36,755,186 Less: Payment to Wasco                                               3,000,000 Less: Payoff of Second Mortgage                             10,000,000             (excludes interest) Net Proceeds from Real Estate                                  $23,755,186 Net Cash Flow                                                             $36,755,186 Less: Payment to Wasco                                               3,000,000 Less: Payoff of Second Mortgage                             10,000,000             (excludes interest) Net Proceeds from Real Estate                                 $23,755,186 Claridge Holdings No. 1- Ownership Position              5.346% Net Proceeds to Claridge Holdings No. 1                   $1,269,952 Internal Rate of Return                                                     -1.370% Claridge Holdings No. 1- Ownership Position                     5.346% Net Proceeds to Claridge Holdings No.1                          $1,269,952 Internal Rate of Return                                                   -16.401% Analysis of Cash Flow Model 2- Scenario 1 9.0 Percent Annual Price Increase- Without CMF Fee Analysis of Cash Flow Model 2- Scenario 2 9.0 Percent Annual Price Increase- With CMF Fee Investor Purchase Price                                                $1,342,000 Investor Purchase Price                                               $2,600,000 Net Cash Flow                                                              $41,783,262 Less:Payment to Wasco                                                 3,000,000 Less: Payoff of Second Mortgage                               10,000,000             (excludes interest) Net Proceeds from Real Estate                                   $28,783,262 Net Cash Flow                                                             $41,783,262 Less: Payment to Wasco                                               3,000,000 Less: Payoff of Second Mortgage                             10,000,000             (excludes interest) Net Proceeds from Real Estate                                 $28,783,262 Claridge Holdings No. 1- Ownership Position              5.346% Net Proceeds to Claridge Holdings No. 1                   $1,538,753 Internal Rate of Return                                                       3.479% Claridge Holdings No. 1- Ownership Position              5.346% Net Proceeds to Claridge Holdings No. 1                 $1,538,753 Internal Rate of Return                                                  -12.290% [67]     It will be obvious that the only way one can arrive at a positive rate of return is if two hypotheses are used:           (a)       no payment of $1,800,000 (Cdn) to CMF;           (b)      an annual price increase of 9%. ...

At some point, the Appellant developed an interest in mineral rights relating to potash. [6]              Sometime in either 2005 or 2006, the Appellant made a $200,000 investment in a company called Athabasca Potash. ... He described it as “ a warm meeting that had connotations of doing business together. ” [12] Mr. ... Minister of Finance (N.S.) [64] referred to the meaning of “ beneficial owner ” as formulated by the trial judge who stated that the term signifies the “ real or true owner ” of the property. ...

B‑3, ss. 2   “property”, 67(1).   Fisheries Act, R.S.C. 1985, c. F‑14, ss. 7(1)  , 9  .   ... In March 2005, the receiver and the trustee in bankruptcy signed an agreement to sell Saulnier’s fishing licences and other assets to a third party for $630,000 (the sale was conditional on the trustee being able to effect a transfer of the licences).  ... Personal Property Security Act, S.N.S. 1995‑96, c. 13     2. In this Act,  ...   ...

“Alain Tardif” Tardif J.     Translation certified true On this 23 rd day of June 2017     François Brunet, Reviser   Citation: 2016 TCC 244 Date: 20161028 Docket: 2014-2611(GST)G BETWEEN: RESTAURANT GIOVANNINA PIZZÉRIA INC., Appellant, and HER MAJESTY THE QUEEN, Respondent. ... Doucet; −                    multiple errors; −                    the electronic system in place at the take-out counter was inadequate, notably due to the fact that it was not connected to the company’s main system; −                    cash register tape that did not provide purchase details; −                    ratio of cost to profit margin; −                    no mention concerning credit notes; −                    duplicate entries; −                    lack of consistency; −                    cash drawer always open. [68]         Taken of context and without further explanation, the list of problems appears to support the auditor’s submission concerning its choice of audit method. [69]         In actuality, however, and in view of the context and highly credible explanations, things appear quite differently. [70]         The auditor took into account information provided by a leading expert in the restaurant industry to guide his work and conclusions. ... Canada, 2005 FCA 425 at paragraph 20). This Court clarified that it is the taxpayer who knows how and why his business is run in a particular fashion rather than in some other ways. ...

.: — Section 118.3 of the Income Tax Act provides a deduction from income tax payable for individuals who suffer from a severe and prolonged mental or physical impairment. ... R., [1996] 2 C.T.C. 2005, the first for the proposition that the basic activities of daily living should be taken to include important ancillary activities, and the second for the proposition that the statutory provision in question should be given as broad an interpretation as it will bear, to alleviate against the rigour of the language of section 118.4. ... I also agree with Judge Bowman’s opinion that the legislation should be interpreted “... with a degree of compassion and understanding that achieves the objective of this section.” ...

The King, 2025 TCC 6 (Informal Procedure)             Docket: 2022-604(I T)I BETWEEN: LEWIS ROSEN, Appellant, and HIS MAJEST Y THE KING, Respondent.     ... Signed a t Toronto, Canada, this 15th day of Januar y 2025.     “Michae l Ezri” Ezri J.             ... (Toronto: LexisNexis Canada, 2022), § 2.04[4]. 4 Canada Trustco v R, 2005 S CC 44, para 10 and 47. 5 Placer Dome v Ontario (Minister of Finance), 2006 SCC 20 para 23 6 Bell ExpressVu Limited Partnership v R, 2002 SCC 42, para 29. ...

Grimes played and continue to play key management roles in SPL, as indicated in paragraph 17 of the Agreed Statements of facts (Exhibit AR‑1). [22]         In 2005, Holdco was created. ... Mandhane, “The Uncertain Duty of the Expert Witness” (2005), 42 Alta. ... Pentney Deputy Attorney General of Canada Ottawa, Canada     ...

Taken together these agreements provided that: (a)            Interest Expense under the Mortgage escalated from 9% at the outset to 15% commencing in 2005, and was based on principal and unpaid interest and was payable monthly. ... " 10.            All other provisions of the Mortgage remained in force. 11.            ... Yours faithfully « signature » A.D. Craig General Manager, Credit Risk Management. ...

The King, 2024 TCC 71 Docket: 2022-3096(IT)G BETWEEN: KATHRYN J CARTER, Appellant, and HIS MAJESTY THE KING, Respondent.   ... Graham DATE OF JUDGMENT: May 16, 2024 APPEARANCES: Counsel for the Appellant: John Loukidelis Counsel for the Respondent: Allan Mason Shane Isler COUNSEL OF RECORD: For the Appellant: Name: John Loukidelis Firm: Loukidelis Professional Corporation Hamilton, Ontario   For the Respondent: Shalene Curtis-Micallef Deputy Attorney General of Canada Ottawa, Canada   [1] Mr. ... The Queen, 97 DTC 111 (TCC). [3] 2005 TCC 203. [4] 2007 TCC 16. [5] 2016 TCC 154. [6] 97 DTC 302 (TCC). [7] Brouillette; McNichol; McMullen; and Poulin. ...