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Following further audits of the gas station business, assessments of the amount outstanding were made for subsequent years, ending in March 31, 2005. ... However, Waycobah did not comply with the repayment agreement and HST collection problems persisted until 2005. ... Wallace FOR THE APPELLANT     Caitlin Ward FOR THE RESPONDENT     SOLICITORS OF RECORD:   McInnes Cooper Halifax, Nova Scotia FOR THE APPELLANT     Myles J. ...

EVANS J.A.                         MALONE J.A.                                                                         ... Canada, 2005 TCC 55 [" McLarty "], a decision of the Tax Court of Canada (the "TCC"). ... V.         ISSUES [26]            There are three broad issues in this appeal: 1.       ...

Appellant and HER MAJESTY THE QUEEN Respondent                 REASONS FOR JUDGMENT OF THE COURT (Delivered from the Bench at Vancouver, British Columbia, on January 17, 2007)     LÉTOURNEAU J.A ...     [1]                These are appeals from a decision of Chief Justice Bowman (Chief Justice) of the Tax Court of Canada (Tax Court) rendered on November 14, 2005. ... The Queen, 2005 TCC 655, par. 5-6 [XCO TCC]). When the Partnership was established in 1986, the partnership agreement established that for both income tax and accounting purposes, the income allocated to the partners would be in accordance with their proportionate interests (Partnership Agreement, Article VII, cited in XCO TCC, ibid, par. 7). [6]                In December 1986, the same month that the Partnership was established, two properties were transferred to the Partnership: the Topaz Apartments and the Westhill Apartments. ...

Ralph Misener (The), [2005] 3 F.C. 367 (C.A.) at paragraph 13).   ANALYSIS The Underlying Context of these Appeals [18]            It is helpful to begin by elucidating the ultimate issues to be resolved between the parties. ... (the “ Act ”).   [19]            In Hammill v. The Queen, 2005 FCA 252, 257 D.L.R. (4 th) 1 (leave to appeal to the S.C.C. refused [2005] S.C.C.A. ... Edgar Sexton" J.A.           "I agree      J.D. Denis Pelletier J.A. ...

  [7]                In Contino v. Leonelli-Contino, 2005 SCC 63; [2005] 3 S.C.R. 217 [Contino], Bastarache J. clearly articulated that the underlining principle relating to child support in the Divorce Act, R.S.C. 1985, c. 3 (2nd Supp.) ... "Johanne Trudel" J.A.       “I agree               Marc Noël J.A.”   ... Pentney Deputy Attorney General of Canada FOR THE RESPONDENT       ...

Innes & Patrick J. Boyle, “Shaky Foundations? A Defence of Special Rules for Private Foundations” (2005), 53 Can. ... Canada, 2005 SCC 54, [2005] 2 S.C.R. 601 at paras. 44, 65-66.   [55]            The Judge found that the purpose of paragraph 118.1(13)(c) was to enable a taxpayer to “redeem” an intended  charitable gift, which did not take effect because it was a “non-qualifying security”, by causing the donee to dispose of the note to an arm’s length third party. ... E.        CONCLUSIONS [62]            For these reasons, I would dismiss the appeal with costs.          ...

NEAR J.A.     BETWEEN: HER MAJESTY THE QUEEN   Appellant and ALLEN BERG   Respondent   Heard at Toronto, Ontario, on September 16, 2013. ...   [21]            As stated in Canada Trustco Mortgage Co. v. Canada, 2005 SCC 54, “[t]he textual, contextual and purposive interpretation of specific provisions of the Income Tax Act is essentially a question of law but the application of these provisions to the facts of a case is necessarily fact-intensive” (paragraph 44).   ... Near" J.A.     “I agree      K. Sharlow J.A.:   “I agree      David Stratas J.A.:             FEDERAL COURT OF APPEAL NAMES OF COUNSEL AND SOLICITORS OF RECORD   Docket:                                                                                                 A-555-12   APPEAL FROM A JUDGMENT OF THE HONOURABLE MR. ...

Doubinin, 2005 FCA 298, [2005] D.T.C. 5624 [Doubinin], at paragraphs 14 to 17, to conclude that the issuance of an inflated tax receipt should not usually be considered as a benefit that negates a gift. [24]            The Judge also concluded that it was not necessary to consider the application of recent amendments to the Act, subsections 248(30), (31), and (32), as the inflated tax receipts were not benefits. ... Canada, 2005 SCC 54, [2005] 2 S.C.R. 601 at paragraph 44: “[t]he textual, contextual and purposive interpretation of specific provisions of the Income Tax Act is essentially a question of law but the application of these provisions to the facts of a case is necessarily fact-intensive”. ... Canada (Minister of National Revenue), 2005 FCA 336, [2006] 1 C.T.C. 35. ...

  [12]            On February 3, 2005, the Canada Revenue Agency disallowed the deduction of $3,576,088 from Perron’s income for the 2001 taxation year. ... CONCURRING REASONS BY:                                        DISSENTING REASONS BY:                                              DATED:                                                                                 July 5, 2013     APPEARANCES:   Ian MacGregor Alain Fournier Alexandra Carbone   FOR THE APPELLANT     Nathalie Goulard Simon Olivier De Launière FOR THE RESPONDENT     SOLICITORS OF RECORD:   OSLER, HOSKIN & HARCOURT LLP, Montréal (Quebec)   FOR THE APPELLANT   William F. Pentney Deputy Attorney General of Canada FOR THE RESPONDENT       ...

EVANS J.A.                         SHARLOW J.A.   BETWEEN: WILLIAM SHAWN DAVITT Appellant   and     THE MINISTER OF NATIONAL REVENUE Respondent       Heard at Toronto, Ontario, on December 8, 2009. ... Canada, 2005 FCA 420). The difficulty here is that Mr. Davitt has chosen the wrong procedure and the wrong court ...   [11]            The appeal will be dismissed with costs.     “K. Sharlow” J.A.                                   ...