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The Respondents, Abraham, Eva, the Siblings, the 1998 Trust, the 201 9 Trusts, AH I and BHL, are collectively referred to by the Applicant as the “ Bleeman Group. ” During the 2019 and 2020 taxation years, the Bleeman Group engaged in estate freeze transactions under sections 51, 85 and/or 86 of the Income Tax Act. ... Moreover, evidence as to whether the documents actually exist — as opposed to representations made in a letter to the CRA as to whether they exist — is what is relevant to the Court’s determination to be made on the underlying application. [33] Questions 602-605 ask Mr. ... “Mandy Aylen”   Judge   ...

Use of Losses [55] The Appellant used non-capital loss carryforwards and net capital loss carryforwards from its mining activities to reduce its income and capital gains from its real estate business by the following amounts in the following years: Tax Year Ending Non-Capital Loss Carryforwards Claimed Net Capital Loss Carryforwards Claimed December 31, 1998 $418,016   December 31, 1999 $1,082,910   December 31, 2000 $2,256,375 $347,133 December 31, 2001 $2,976,801 $1,705,743 December 31, 2002 $1,199,429 $4,151,138 December 31, 2003   $254,594 December 31, 2004 $2,437,465 $1,341,068 December 31, 2005 $2,540,311 [14] $546,877 December 31, 2006   $9,478,309 December 31, 2007   $13,200,287 December 31, 2009 $7,539,680 December 31, 2011   $1,156,686 August 31, 2013   $3,773,141   [56] Only the last three taxation years are before me. ... Davies   Firm: Thorsteinssons LLP For the Respondent: Shalene Curtis-Micallef Deputy Attorney General of Canada Ottawa, Canada   [1] Copthorne Holdings Ltd. v. ... The percentage is calculated as follows: 6.02% = (6,700,000 / [6,700,000 + 1,600,000 + 102,994,839]). [3] I had difficulty with parts of Mr. ...

“Réal Favreau” Favreau J.       Docket: 2013-1220(EI) BETWEEN: KELLY GODIN, Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent.   ... Godin submitted the following documents: −          the registration of his three boats used for fishing lobster and herring; −          invoices for the delivery of baits to the Arseneau Fish Market which show that he was in operation during the month of April of each year; −          the truck inspection reports showing that he had six or seven trucks in 2007; −          a map showing from where he purchased crabs; −          receipts from Arseneau Fish Market showing trips made by Lucien Carrier; −          purchase and sale of lobsters by Jacques Doucet; −          the timesheets prepared by Tracy Esliger; −          payments for the purchases of lobster for three years; −          T-4 slips prepared by Tracy Esliger issued to crab fishermen; −          receipts for wood delivered to Bathurst in 2010 but cut in 2009; −          receipts from the Arseneau Fish Market showing that he was still in operation during the month of July of each year. [20]         Every April, Mr. ... McIntyre For the Intervenor: The Intervenor herself   COUNSEL OF RECORD: For the Appellant: Name:     Firm:   For the Respondent: William F. ...

Droit applicable [15] L’alinéa 5(1)a) de la LAE précise qu’un « emploi assurable » inclut un « emploi exercé au Canada pour un ou plusieurs employeurs, aux termes d’un contrat de louage de services » sans toutefois définir ce qu’est un contrat de louage de services. ... Au fil des prochaines années, ses commissions ont augmenté à 100 000 $, 150 000 $ et au-delà. ... Laurier, 12e étage Québec (Québec) G1V 0B9 Pour l’intimé: François Daigle Sous-procureur général du Canada Ottawa, Canada     ...

MNR, 2015 TCC 250, ¶26 & 28. See also City Water, supra note 99, ¶14 & 24; and Hennick v. ... MNR, 2005 TCC 178, ¶ 33. [105] Transcript, vol. 1, p. 20, lines 13-18; vol. 1, p. 45, lines 9-12; and vol. 1, p. 80, lines 21-26. [106] Transcript, vol. 1, p. 80, line 27 to p. 81, line 7; vol. 2, p. 178, line 25 to p. 179, line 15; and vol. 2, p. 190, lines 5-17. [107] DHL Express, supra note 104, ¶ 32. ... Victoria Amateur Swimming Club, 2005 BCSC 778, ¶12; TCF Ventures Corp. v. ...

Abbott and Haliburton Co., 2015 SCC 23 (“ Inman ”). Inman confirms and clarifies the common law principles previously described by the Supreme Court of Canada in R. v. ... The calculation for the 2010 Taxation Year is as follows:     Filed by Taxpayer Assessed by the CRA         Total SR&ED Expenditures   $587,005 $171,979 Add:       Prescribed Proxy Amount 65% $365,003 $111,786 Deduct       Government Assistance- OITC   $88,705 $11,179 Government Assistance- IRAP   $65,261 $171,979         Qualified Expenditures for ITC   $798,342 $100,607         ITC 35% [18] $279,420 $35,212   [218] The calculation for the 2011 Taxation Year is as follows:     Filed by Taxpayer Assessed by the CRA         Total SR&ED Expenditures   $418,890 $120,635 Add:       Prescribed Proxy Amount 65% $272,279 $78,413 Deduct       Government Assistance- OITC   $68,834 $16,945 Government Assistance- IRAP   $6,829 $29,598         Qualified Expenditures for ITC   $615,506 $152,505         ITC 35% $215,567 $53,377   [219] The Appellant did not provide the details of its calculation of the amounts claimed on its tax returns. ... Both the Appellant and the Minister calculated the OITC government assistance as 10% of the following: Allowable SR&ED expenditures Plus: prescribed proxy amount Less: IRAP assistance received in respect of SR&ED. [23] [247] Applying this calculation to the amounts determined by the Court results in OITC government assistance of $49,986 in the 2010 Taxation Year and $56,483 in the 2011 Taxation Year. [248] On the basis of the above, the Appellant incurred qualifying SR&ED expenditures of $449,878 and $508,351 in the 2010 and 2011 taxation years, respectively, and is entitled to corresponding ITCs of $157,457 and $177,923 for the 2010 and 2011 taxation years, respectively, calculated as follows:     2010 Taxation Year 2011 Taxation Year         Total SR&ED Expenditures   $425,911 $355,891 Add:       Prescribed Proxy Amount 65% $276,842 $231,329 Deduct       Government Assistance- OITC   $49,986 $56,483 Government Assistance- IRAP   $202,889 $22,386         Qualified Expenditures for ITC   $449,878 $508,351         ITC 35% $157,457 $177,923   [249] For the foregoing reasons, the appeals are allowed with costs and the reassessments are referred back to the Minister for reconsideration and reassessment on the basis that the Appellant incurred qualifying SR&ED expenditures of $449,878 and $508,351 in the 2010 and 2011 taxation years, respectively, and is entitled to corresponding ITCs of $157,457 and $177,923 for the 2010 and 2011 taxation years, respectively. ...

Hodgins, on October 6, 2011: … I … described to Tim my desire for a loss, … or a deferral, to create the deferral. ... Walls, 2002 SCC 47, ¶ 19. Compare with Stewart, supra note 180, ¶ 53. ... Canada Trustco Mortgage Company, [2005] 2 S.C.R. 601, ¶ 21; S.T.B. Holdings Ltd. v. ...

D’Arcy Appearances:   Counsel for the Appellant: Bobby Solhi Frédérique Duchesne Counsel for the Respondent: Robert Zsigo   JUDGMENT In accordance with my reasons for judgment:   The appeal from an assessment made under the Excise Tax Act by Notice of Assessment dated January 14, 2019 is dismissed with costs. ... The question before the Court is whether, in such a situation, the sale of the condominium unit was subject to GST/HST. [2] The parties filed an Agreed Statement of Facts (the “ ASF ”) and a joint book of documents. ... E-15 (the “ GST Act ”). It is an annual filer, with a reporting period ending on May 31 of each year. ...

., [1990] 2 C.T.C. 2005, 90 D.T.C. 1499. Rather it is a question of an obligation which forms an integral part of agreements reached between the spouses and ratified in the terms and conditions of the judgment of divorce itself. ... However, it is not very difficult to reconstruct the figures on which the assessment was probably based: 115 x $150 $17,250 $14,000 x $7,800 = $6,330 $17,250 The figure is the fraction of the maximum amount of weekly payments which would otherwise have been made in 1990, that is $7,800, which half the selling price of the house, that is $14,000, represents of the total amount of weekly payments, that is $17,250, which would otherwise have been made during the 115 weeks during which the periodic payments were suspended. ...

However, no source deductions were made by the union from the amounts so paid and no T-4 information slips issued indicating the amounts paid. [4] The appellants failed to report the amounts in question and in October 1996, after contacting the union, the Minister of National Revenue ("the Minister") assessed the unreported amounts, adding not only interest, but also penalties pursuant to s. 163(2) of the Income Tax Act ("the Act"). [5] The relevant particulars concerning each of the appellants are as follows: Name Year Unreported amount Penalty Denis Comptois 1994 $ 1,369.00 $100.00 France Morin 1992 $13,297.00 $479.96 1993 $10,513.00 $747.89 1994 $ 1,363.00 $100.00 Pierre Daoust 1992 $ 9,065.00 $994.72 1995 $ 1,681.00 $192.06 Marcel Martin 1994 $ 8,413.00 $600.57 1995 $ 4,891.00 $349.08 François Deschênes 1994 $ 6,158.00 $439.13 1995 $ 4,477.00 $319.36 [6] Except in the cases of France Morin and Pierre Daoust, only the penalties are in dispute, on the ground that the failure to report was not due to gross negligence by the appellants. ... No opening.- 0 fine to union, 0 fine individuals ® union to be responsible.- Rectify situation (regularize).- 1992, 1993, 1994 amounts paid each year for each person involved in union....- Revenue Quebec would have to follow.... [31] Ms. ... The Queen), 97 DTC 487, [1997] 1 C.T.C. 2005 (T.C.C.).- The Queen v. Regina Shoppers Mall Limited, 91 DTC 5101, [1991] 1 C.T.C. 297 (F.C.A.). ...