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THE DECISION UNDER APPEAL [3]                The Minister appeals the August 4, 2005 order of a Federal Court judge (the Applications Judge) that quashed a requirement letter dated July 20, 2004, issued by an officer in the Special Enforcement Program (SEP), a unit within the Investigations Division of the Canada Revenue Agency (CRA). ... Prince Edward Island College of Optometrists, 2005 SCC 77). [18]            I turn now to an analysis of the Jarvis factors relevant to the Requirement issued to Mr. ...   [35]            In this circumstance, the appeal should be allowed, the order of the Applications Judge dated August 4, 2005 should be set aside and the Requirement issued by the CRA on July 20, 2004 should be restored. ...

Hamdane, in the summer of 2005. None of the other workers made such a request ... Hamdane held insurable employment with the appellant during the period November 1, 2004 and June 16, 2005 (Appeal Book, Vol. ...   [53]            In 9041-6868 Québec Inc. v. Canada (Minister of National Revenue--   M.N.R.), 2005 FCA 334, Décary J.A. for the Court indicated, at paragraph 12 of his reasons, that: […] in Quebec civil law, the definition of a contract of employment itself stresses "direction or control" (art. 2085 C.C.Q.), which makes control the actual purpose of the exercise… ...

MARENGÈRE Appellant and HER MAJESTY THE QUEEN Respondent REASONS FOR JUDGMENT OF THE COURT (Delivered from the Bench at Montréal, Quebec, on February 8, 2006) NADON J.A. [1]                These are consolidated appeals from a decision of Bédard J. of the Tax Court of Canada dated February 23, 2005, (Matossian v. Canada, [2005] T.C.J. No. 93 (Q.L.), 2005 TCC 21), which dismissed the appellants' appeals from assessments issued by the Minister of Revenue under the Income Tax Act (the "Act"). [2]                Specifically, the Minister assessed the appellants, who were at all material times directors of Dominion Bridge Inc. ... FEDERAL COURT OF APPEAL NAMES OF COUNSEL AND SOLICITORS OF RECORD DOCKETS:                                                                             A-130-05, A-131-05, A-132-05 Appeal from the order of the honourable Paul Bédard, of the Tax Court of Canada dated February 23, 2005 in Court file 2001-1332(IT)G. ...

Canada (Canada Customs and revenue agency), 2010 FCA 214 Federal Court of Appeal   Cour d'appel fédérale   Date: 20100824 Docket: A-71-05 Citation: 2010 FCA 214   [ENGLISH TRANSLATION] BETWEEN: PIERRE ARCHAMBAULT Appellant and CANADA CUSTOMS AND REVENUE AGENCY Respondent       ASSESSMENT OF COSTS – REASONS   [1]                On February 10, 2006, the Federal Court of Appeal dismissed with costs the appeal from the Federal Court’s decision made on February 7, 2005, dismissing with costs the application for judicial review filed by Pierre Archambault ...   [3]                The respondent seeks the following fees: Item 19 – memorandum of fact and law (7 units), Item 21 – counsel fees: preparation of a reply record to the appellant’s motion for determining the content of, and preparing, the appeal record (see order dated April 28, 2005) (3 units), Item 22(a) – counsel fees during the appeal hearing for the first counsel for each hour at the Court on February 8, 2006, from 2:28 p.m. to 3:48 p.m. (3 units x 1.33 hrs.), Item 24 – travel by counsel to a hearing (5 units) and Item 26 – assessment of costs (6 units) ... A certificate of assessment will be issued for this amount.   MONTRÉAL, QUEBEC August 24, 2010       “Diane Perrier” DIANE PERRIER ASSESSMENT OFFICER     FEDERAL COURT OF APPEAL   NAMES OF COUNSEL AND SOLICITORS OF RECORD       DOCKET:                                                                               A-71-05   STYLE OF CAUSE:                                                               PIERRE ARCHAMBAULT v. ...

  [8]                In this case, C.B. Powell imported bacon bits from the United States in 2005. ... Canada, [2005] 1 S.C.R. 146, 2005 SCC 11 at paragraphs 1-2; Okwuobi v. ... Pearson School Board, [2005] 1 S.C.R. 257, 2005 SCC 16 at paragraphs 38-55; Canada (House of Commons) v. ...

An order dated April 1, 2005 did award costs to the Crown further to the Appellant’s unsuccessful motion for summary judgment. ...   [5]                It follows in this matter that the claim under fee item 25 must be disallowed as that service relates to a final disposition (the January 5, 2006 order) as opposed to an interlocutory disposition (the April 1, 2005 order). ... STINSON   DATED:                                                                                 October 17, 2008       WRITTEN REPRESENTATIONS BY:   John Scott Manson FOR THE APPELLANT (self-represented)   Marta Burns   FOR THE RESPONDENTS     SOLICITORS OF RECORD:   n/a FOR THE APPELLANT (self-represented)   John H. ...

Date: 20060619 Docket: A-436-05 Citation: 2006 FCA 230 CORAM:        NOËL J.A.                         NADON J.A.                         SEXTON J.A. BETWEEN: SUKHDEV SINGH Appellant and HER MAJESTY THE QUEEN Respondent REASONS FOR JUDGMENT OF THE COURT (Delivered from the Bench at Toronto, Ontario, on June 19, 2006) NOËL J.A. [1]                This is an appeal from a judgment of Woods J. of the Tax Court of Canada (2005 TCC 588) dismissing Mr. ... WOODS, TAX COURT OF CANADA, DATED AUGUST 31, 2005) STYLE OF CAUSE:                                                   SUKHDEV SINGH v. ...

INTRODUCTION [1]                This is an appeal from the Tax Court ([2005] 4 C.R.T. 2070) in respect of lodging and automobile expenses reimbursed to an employee by the employer. [2]                The Tax Court judge dismissed the appellant's appeal in respect of these expenses, finding that the Minister properly assessed them as taxable benefits. ... However, the Minister does not dispute the appellant's recounting of what transpired. [6]                The Minister's January 12, 2005 Reply to the appellant's Notice of Appeal in the Tax Court stated that the statutory provisions upon which the Minister would be relying were paragraphs 6(1)(a), 6(1)(b) and 6(1)(k) of the Income Tax Act. [7]                At the commencement of the proceedings in the Tax Court on July 8, 2005, counsel for the Minister, without any advance notice and without formal motion, requested that he be permitted to file an amended Reply in which the reference to paragraph 6(1)(k) was deleted and 6(1)(l) substituted. [8]                Paragraph 6(1)(l) is the provision that requires that benefits an employee receives from his employer for the operation of an automobile must be included in the employee's income as a taxable benefit. ... He explained that as the issues involved his 2000 and 2001 taxation years and the case before the Tax Court judge took place in 2005, he did not want to incur further delay. [11]            The appellant says that the Tax Court judge should have refused the Minister's application to file an amended Reply on the morning of the trial. ...

Appellant   and   MINISTER OF NATIONAL REVENUE Respondent               REASONS FOR JUDGMENT WEBB J.A. [1]                These are appeals from two decisions of the Tax Court of Canada (2011 TCC 237) rendered by Rip C.J. ...   [9]                In Zupet v. The Queen, 2005 TCC 89, Bowman A.C.J. ... Pentney Deputy Attorney General of Canada FOR THE RESPONDENT           ...

Justice Dussault of the Tax Court of Canada (2005 DTC 689) confirming the validity of an assessment made in regard to its 1998 taxation year. ...   [13]      On April 26, 2005, the Tax Court of Canada dismissed the appeal and upheld the assessment.   ... DUSSAULT OF THE TAX COURT OF CANADA DATED APRIL 26, 2005, DOCKET NO. 2001-4281 (IT)G   STYLE:                                                           La Survivance v. ...