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  [2]                Jolly Farmer Products Inc. appealed its reassessments for the 1998, 1999, 2000, 2001, 2002 and 2003 taxation years on May 30, 2005 (“Corporate Appeal”) ...   [23]            The Reassessments for the Corporate Appellant relate to 1998, 1999, 2000, 2001, 2002 and 2003 taxation years, the Reassessments for the Shareholder Appellants relate to 2000 and 2001 taxation years, and the Corporate and Shareholder Appeals were commenced in 2005. ...   [25]            Accordingly, the Appellants’ motion for a stay of the Order will be dismissed with costs.             ...

Au, 2006 FCA 28 Date: 20060124 Docket: A-241-05 Citation: 2006 FCA 28 CORAM:        DÉCARY J.A.                         ... FEDERAL COURT OF APPEAL NAMES OF COUNSEL AND SOLICITORS OF RECORD DOCKET:                                           A-241-05 Appeal from a Judgment of the Tax Court of Canada dated April 29, 2005. ... PETER AU                                                                                                                   Respondent PLACE OF HEARING:                     OTTAWA, ONTARIO DATE OF HEARING:                       JANUARY 24, 2006 REASONS FOR JUDGMENT OF THE COURT:                               (DÉCARY, ROTHSTEIN, SHARLOW JJ.A.)             ...

(CSI) from 2005 to June 6, 2008. •          During his employment with CSI, the appellant was granted the option to purchase 116,000 shares of CSI. •          In the 2008 taxation year, the shares of CSI were listed on the NASDAQ stock exchange, an American stock exchange. •          Upon the appellant’s resignation from CSI on June 6, 2008, the appellant ceased to be a resident of Canada for income tax purposes. •          On September 4, 2008, the appellant exercised his option to purchase 53,150 shares of CSI. •          On November 17, 2008, the appellant sold 25,000 shares at a price of $5.9065 (U.S.) per share. •          The next day, on November 18, 2008, the appellant sold the remaining 28,150 shares of CSI at a price of $5.3658 (U.S.) per share. •          As a result of the November 17 and 18, 2008, transactions, the appellant suffered a loss of $1,247,657. •          The appellant completed the November, 2008 trades through a stock broker based in the United States. [10]            The appellant submits that when an individual lists shares of a publicly listed corporation for sale on a particular stock exchange, the individual makes the share available to anyone who is willing to purchase the share, without any territorial restriction. ... Canada, 2005 TCC 66, 2005 D.T.C. 514, at paragraph 34; aff’d 2006 FCA 35, 354 N.R. 272). [14]            For these reasons, I would dismiss the appeal with costs. ... Pentney Deputy Attorney General of Canada   For The Respondent     ...

Those corrections were filed on August 8, 2005. The stated reason for the corrections was: VOLUNTARY AMEND. ... EXPENSES, CCI, INVOICE, LETTER FROM VENDOR ENCLOSED. [22]            On August 24, 2005, the Agency issued to Fritz 21 Detailed Adjustment Statements pursuant to subsection 59(1) of the Customs Act. ... I would set aside the order under appeal for want of jurisdiction and, making the order that should have been made by the Federal Court, I would dismiss with costs the application of Fritz Marketing Inc. to set aside the Detailed Adjustment Statements issued to it on August 24, 2005.       ...

LÉTOURNEAU J.A.                         EVANS J.A.   BETWEEN: ROYAL BANK OF CANADA Appellant and   HER MAJESTY THE QUEEN   Respondent and   THE CANADIAN BANKERS ASSOCIATION   Intervenor       REASONS FOR JUDGMENT OF THE COURT (Delivered from the Bench at Toronto, Ontario, on February 14, 2007) LÉTOURNEAU J.A. [1]                This is an appeal against a decision of Bowie TCCJ (Judge) of the Tax Court of Canada rendered on April 21, 2005.  ... FEDERAL COURT OF APPEAL   NAMES OF COUNSEL AND SOLICITORS OF RECORD   DOCKET:                                                       A-27-06   (APPEAL FROM AN ORDER OF THE HONOURABLE JUSTICE BOWIE, TAX COURT OF CANADA, DATED DECEMBER 20, 2005, 2002-2478(GST)G)   STYLE OF CAUSE:                                      ROYAL BANK OF CANADA                                                                                     Appellant                                                                         and   HER MAJESTY THE QUEEN Respondent                                                                         and                                                                           THE CANADIAN BANKERS                                                                         ASSOCIATION Intervenor   DATE OF HEARING:                                   FEBRUARY 14, 2007   PLACE OF HEARING:                                 TORONTO, ONTARIO   REASONS FOR JUDGMENT OF THE COURT BY:                                    (D É CARY, L É TOURNEAU & EVANS JJ.A.)   ... Laskin Gillian Dingle   For the Respondent     For the Intervenor       SOLICITORS OF RECORD:   OSLER, HOSKIN & HARCOURT LLP Barristers & Solicitors Toronto, ON     For the Appellant   John H. ...

STRATAS J.A.                         NEAR J.A.   BETWEEN: JAMES G. MULLEN Appellant and   HER MAJESTY THE QUEEN Respondent       Heard at Toronto, Ontario, on April 15, 2013. ... The Queen, 2004 CCI 230 at paragraph 33, approved on this point at 2005 FCA 162 at paragraph 4 ... DELIVERED FROM THE BENCH BY:                          Stratas J.A.       ...

Canada, 2005 SCC 54, [2005] 2 S.C.R. 601, at para. 17 [Trustco]. The question whether there is a tax benefit or whether the existence of a series of avoidance transactions has been established gives rise to a question of fact with respect to which the trial court is entitled to deference: Trustco at paras. 19, 44; Housen v. ... Gendron acquired by way of the gift – 0 cents – and by way of the share purchase – $1,00. ... Drouin Deputy Attorney General of Canada For the Respondent     ...

DÉCARY J.A.                         LÉTOURNEAU J.A.   BETWEEN: ANDRÉ GAGNÉ Appellant and ATTORNEY GENERAL OF CANADA Respondent               Hearing held at Montréal, Quebec, on December 12, 2007. ... The fact remains however that the appellant’s explanations could not compensate for the lack of evidence in the record of an existing operational and operating business, or for the absence of an accounting system determining the revenues and expenses of the business: see the reasons of the fiscal authorities sent to the appellant by letter dated December 2, 2005, at page 56 of the appeal record ... DÉCARY J.A.     DATE OF REASONS:                                   December 13, 2007       APPEARANCES:   André Gagné Montréal, Quebec   FOR THE APPELLANT (representing himself)   Kim Sheppard FOR THE RESPONDENT     SOLICITORS OF RECORD:   John H. ...

  [29]            Mr. Jenkins replied to the December 22, 2004 correspondence from the RPD with a final letter on January 5, 2005. ...   [30]            On September 8, 2005, the CRA issued the Notice of Intent stating as follows: The Minister intends to revoke the Plan’s registration effective August 1, 1999 because:   It appears that the Plan fails to satisfy paragraph 8502(a) of the Regulations, one of the prescribed conditions for registration set out in paragraph 8501(1)(a) of the Regulations. ... Canada (Minister of National Revenue – M.N.R.), [2005] F.C.J. No. 1551, 2005 FCA 304. ...

Notices of Reassessment for each of the 1996 and 1997 taxation years were issued on November 30, 2004 and on May 3, 2005. ... [22]       I begin by noting that while the Judge ordered the production of internal CRA memoranda prepared from 2000 to July 2007, during oral argument counsel for Lehigh significantly narrowed the relevant timeframe to be from the date of the Gulliver memorandum (May 2, 2002) to the date of the assessments (November 30, 2004 and on May 3, 2005). ... Canada (Attorney General), 2005 SCC 26, [2005] 1 S.C.R. 533 at paragraphs 45 to 47 and 155 to 157 ...