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BETWEEN:   LOVING HOME CARE SERVICES LTD.   Appellant   And   MINISTER OF NATIONAL REVENUE AND LA-TOYA LANA BURT   Respondents   Heard at Vancouver, British Columbia, on March 9, 2015. ... BETWEEN:   LOVING HOME CARE SERVICES LTD.   Appellant   And   MINISTER OF NATIONAL REVENUE AND LA-TOYA LANA BURT   Respondents   REASONS FOR JUDGMENT WEBB J.A. [1]                These are appeals from the judgments of Boyle J. (2014 TCC 71) issued in relation to the appeals of Loving Home Care Services Ltd. ... Canada, 2005 SCC 25; [2005] 1 S.C.R. 301, Fish J. writing on behalf of the majority of the Supreme Court of Canada noted that: 74         I would explain the matter this way. ...

Hillier leave to appeal from the decision of the General Division under section 58 of the Department of Employment and Social Development Act, S.C. 2005, c. 34. ... Canada, 2005 SCC 54, [2005] 2 S.C.R. 601 at para. 10. [19]   The words of the relevant provisions of the Department of Employment and Social Development Act —section 58 in particular—seem precise and unequivocal. ... On occasion, words that, at first glance, seem clear, can admit of ambiguity after broader examination: Montréal (City) v. 2952-1366 Québec Inc., 2005 SCC 62,  [2005] 3 S.C.R. 141 at para. 10; Canada Trustco, above at para. 47. [25]   The need to examine purpose and context, however, is not a licence to overlook legislative text that is genuinely clear and unambiguous. ...

Canada, 2005 SCC 54 at para. 11, [2005] 2 S.C.R. 601 [Canada Trustco]. ... Frye, 2005 FCA 264 at para. 28, 141 A.C.W.S. (3d) 660. [19]            The singular meaning of the English version of the definition, which states that a qualifying institution need merely be recognized as one that is empowered to grant degrees, is encompassed in the French definition, if it is equivocal. ... HER MAJESTY THE QUEEN     PLACE OF HEARING: Vancouver, British Columbia   DATE OF HEARING: September 21, 2016   REASONS FOR JUDGMENT BY: GLEASON J.A.   ...

SCOTT J.A.   BETWEEN:   FIDUCIE ALEX TRUST   Appellant   And   HER MAJESTY THE QUEEN   Respondent   Heard at Montréal, Quebec, on May 12, 2014. ... SCOTT J.A.   BETWEEN:   FIDUCIE ALEX TRUST   Appellant   And   HER MAJESTY THE QUEEN   Respondent   REASONS FOR JUDGMENT OF THE COURT (Delivered from the Bench at Montréal, Quebec, on May 12, 2014.) ... Canada, 2005 FCA 252, 257 D.L.R. (4th) 1 (leave to appeal to the Supreme Court of Canada denied), at paragraphs 29 to 32: [29]     Specifically, the appellant argues that the Tax Court Judge was bound by the facts as admitted, even if contrary evidence was adduced at trial. ...

The basis of the assessment was that, from January 1, 1999 to June 6, 2005, Mr. ... He gave these documents to the Trustee in September of 2005. He picked up five returns and gave the information to the Trustee to prepare the returns as seen in Tab 12 of Exhibit R-1. ... Doncaster’s diagnosis, the likelihood that he suffered from ADHD during the relevant period (1999 to 2005), or whether ADHD affected or could have affected him during that period in a manner that is relevant to a due diligence defence. ...

The Queen, 2005 FCA 393, [2005] F.C.J. No. 1952: 15      An application for judicial review may be made to the Federal Court to challenge the legality of collection measures taken by the Minister to collect taxes allegedly due. [47]            This was reaffirmed by this Court in JP Morgan at paragraph 96. [48]            As a result, the Federal Court does have the jurisdiction to judicially review the collection action of the Minister in issuing the RTP in this case. ... Canada Trustco Mortgage Company, 2005 SCC 54, [2005] 2 S.C.R. 601: 10        It has been long established as a matter of statutory interpretation that “the words of an Act are to be read in their entire context and in their grammatical and ordinary sense harmoniously with the scheme of the Act, the object of the Act, and the intention of Parliament”: see 65302 British Columbia Ltd. v. ... Johnston   For The Respondent   SOLICITORS OF RECORD: Legacy Tax + Trust Lawyers Vancouver, British Columbia   For The Appellant   Department of Justice Vancouver, British Columbia   For The Respondent     ...

  [16]            For these reasons, I would dismiss the appeal with only one set of costs, but with entitlement to disbursements in each case.       ... Denis Pelletier J.A.           Certified true translation François Brunet, LLB, BCL       FEDERAL COURT OF APPEAL   SOLICITORS OF RECORD       DOCKETS:                                               A-352-05, A-353-05   APPEAL FROM A DECISION BY JUDGE LUCIE LAMARRE OF THE TAX COURT OF CANADA OF JULY 7, 2005, CASE No. 2002-4863(GST)G.   ... DATED:                                                    May 3, 2006     APPEARANCES:   Richard Généreux FOR THE APPELLANT   Gérald Danis FOR THE RESPONDENT     SOLICITORS OF RECORD:   Généreux, Côté, solicitors Drummondville, Quebec   FOR THE APPELLANT   Veillette, Larivière Montréal, Quebec FOR THE RESPONDENT     ...

Quigley against his reassessments under the Income Tax Act for the 2004 and 2005 taxation years. ...     [8]                In our respectful view, the Judge erred in dismissing the Crown’s motion with respect to the taxation years 2004 and 2005. ...   [11]            For these reasons, the appeal will be allowed, the order of the Tax Court set aside with respect to the taxation years 2004 and 2005, and the Crown’s motion to quash Mr Quigley’s appeal of his income tax reassessments for the taxation years 2004 and 2005 allowed. ...

Justice Angers of the Tax Court of Canada (2005 TCC 256), dated May 17, 2005, dismissing the motions for an extension of time to serve a notice of objection to the notices of assessment issued by the respondent for the period from January 1, 1992, to September 30, 2000 ...   [21]            I would dismiss the two appeals with a single set of costs.       ... NADON J.A.       DATE OF REASONS:                                                           November 30, 2006     APPEARANCES:     FOR THE APPELLANT   Philippe Morin FOR THE RESPONDENT     SOLICITORS OF RECORD:     FOR THE APPELLANT   Veillette et associés, Sainte-Foy, Quebec FOR THE RESPONDENT     ...

(the Act) with respect to its 2003, 2004, 2005, and 2006 taxation years. [2]                The legislative provisions relevant to the analysis are reproduced in Annex I to these reasons. ... HER MAJESTY THE QUEEN     PLACE OF HEARING: Montréal, Quebec   DATE OF HEARING: June 21, 2016   REASONS FOR JUDGMENT BY: NOËL C.J.   ... Montréal, Quebec   For The Appellant   William F. Pentney Deputy Attorney General of Canada For The Respondent     ...