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In the words of Justice Sheridan at paragraph 4 in the trial decision of Dumont (2005 TCC 790 at paragraph 4) for these very reasons the "argument that Treaty 8 shelters... income from taxation is without merit. ... In Dumont “the Appellant's only response to Benoit was that he disagreed with it and urged this Court to reject the decision” (paragraph 4 of the decision of the Tax Court 2005 TCC 790). ... HER MAJESTY THE QUEEN     PLACE OF HEARING: Ottawa, Ontario   DATE OF HEARING: June 18, 2014   REASONS FOR JUDGMENT BY: WEBB J.A.   ...

BETWEEN: CLAIRE LISTER Appellant and HER MAJESTY THE QUEEN Respondent     REASONS FOR JUDGMENT SHARLOW J.A. [1]                This is an appeal by Claire Lister, and a cross appeal by the Crown, of a judgment of the Tax Court of Canada (2005 TCC 113), rendered under the informal procedure of that Court in relation to Ms. ... Lister on the cross-appeal.     “K. Sharlow” J.A.     “I agree      J.D. ... Deputy Attorney General Of Canada FOR THE RESPONDENT               ...

CONCURRED IN BY:                                                                                                   SEXTON J.A.             ... "I agree.           J. Edgar Sexton" "I agree.           ... Malone" FEDERAL COURT OF APPEAL NAMES OF COUNSEL AND SOLICITORS OF RECORD DOCKET:                                                                               A-13-05 (APPEAL FROM A JUDGMENT OF THE TAX COURT OF CANADA DATED JANUARY 4, 2005, NO. 2004-2301(IT)I). ...

In this proceeding, Grand River appeals from 23 assessments of excise duty plus interest relating to a 23 month period commencing in September, 2005 and continuing to July, 2007. 4.       ... Dawson” J.A.     “I agree             Carolyn Layden-Stevenson J.A.”   ... McNeil   FOR THE APPELLANT   Mr. André LeBlanc FOR THE RESPONDENT     SOLICITORS OF RECORD:   1) Millar Kreklewetz LLP     Toronto, Ontario   2) Inch Hammond Professional Corporation     Hamilton, Ontario   FOR THE APPELLANT   Myles J. ...

BOIVIN J.A.   BETWEEN:   IMMUNOVACCINE TECHNOLOGIES INC.   Appellant   and   HER MAJESTY THE QUEEN   Respondent   Heard at Halifax, Nova Scotia, on September 9, 2014. ... BOIVIN J.A.   BETWEEN:   IMMUNOVACCINE TECHNOLOGIES INC.   Appellant   and   HER MAJESTY THE QUEEN   Respondent   REASONS FOR JUDGMENT BOIVIN J.A. [1]                The appellant appeals from a decision of Lamarre J. (the Judge) of the Tax Court of Canada, dated April 10, 2013. [2]                The Judge upheld the decision of the Minister of National Revenue that the payments the appellant received from the Atlantic Canada Opportunities Agency (ACOA) for the tax years 2005, 2006, 2007, and 2008 were “government assistance” pursuant to subsection 127(9) of the Income Tax Act, R.S.C. 1985, c. 1 (5 th Supp.) ...

E-15 for the 2004, 2006 and 2007 taxation years and allowed those for the 2003 and 2005 taxation years only for the purpose of adjusting the underreported income to reflect the respondent’s concessions. [2]                The Judge found that the appellant had unreported income of $3,669,458 and that he had not demonstrated that the source of the unreported funds was not taxable. ... HER MAJESTY THE QUEEN     PLACE OF HEARING: Toronto, Ontario   DATE OF HEARING: December 7, 2016   REASONS FOR JUDGMENT BY: NEAR J.A.   ... RENNIE J.A.   DATED: December 15, 2016   APPEARANCES: Jason Rosen Jeff Kirshen   For The Appellant   John Grant Rishma Bhimji   For The Respondent   SOLICITORS OF RECORD: Rosen Kirshen Tax Law Toronto, Ontario   For The Appellant   William F. ...

WOODS J.A.     BETWEEN: PAUL LAUZON Appellant and HER MAJESTY THE QUEEN Respondent Heard at Toronto, Ontario, on November 23, 2016. ... Lauzon’s entire tax for the years 2005 to 2008 would be refunded. [4]                In a reassessment for the 2008 taxation year, the Minister of National Revenue denied the deduction and imposed a gross negligence penalty. [5]                As it turned out, the losses were totally fictitious, having been made up by the tax return preparer from Fiscal Arbitrators. ... Pentney Deputy Attorney General of Canada For The Respondent   ...

WOODS J.A.     BETWEEN: 1218395 ONTARIO INC. Appellant and HER MAJESTY THE QUEEN Respondent Heard at Toronto, Ontario, on June 13, 2017. ... E-15 for the reporting periods between January 1, 2001 to December 31, 2001, and from reassessments under the Income Tax Act, R.S.C., 1985, c. 1 (5th Supp.) in respect of the appellant’s taxation years 1998 to 2005. [2]                We also have a motion for leave to file new evidence pursuant to Rule 351 of the Federal Courts Rules, SOR/98-106, which was referred to the panel hearing the merits of this appeal. [3]                The TCC quashed the appeals referred to above on the basis that the appellant has no legal status to initiate legal proceedings due to the fact that it had lost its corporate charter on or about March 27, 2006 (when its charter was revoked under the Ontario Business Corporations Act, R.S.O. 1990, c. ... Pentney Deputy Attorney General of Canada For The Respondent   ...

Effective April 1, 2005, the fees payable under the FSA became a revenue sharing payment. [11] It is not clear from the partial agreed statement of facts whether all the fees under the FSA were paid to PC Bank. The agreed statement of facts states, in paragraph 8, that “[u]ntil April 1, 2005, CIBC was obliged to pay to [Loblaw] (and then PC Bank) fees calculated by reference to each new account …”. ... HIS MAJESTY THE KING   AND DOCKET: A-161-22   STYLE OF CAUSE: CANADIAN IMPERIAL BANK OF COMMERCE v. ...

Canada, 2005 SCC 54, [2005] 2 S.C.R. 601 at paras. 11-12). [23]   Thus, according to the Tax Court judge, paragraph 110.1(1)(d) allowed the appellant to claim the ecological gift deduction for its 2008 through 2013 taxation years and so the appellant’s 2014 taxation year falls outside the carryforward period (Reasons, para. 44). ... HER MAJESTY THE QUEEN     PLACE OF HEARING: Heard by online videoconference   DATE OF HEARING: SEPTEMBER 29, 2020   REASONS FOR JUDGMENT BY: NOËL C.J.   ... LEBLANC J.A.   DATED: NOVEMBER 10, 2020   APPEARANCES: Dominic C. Belley Nicolas Benoît-Guay   For The Appellant Selena Sit Max Matas   For The Respondent SOLICITORS OF RECORD: Norton Rose Fulbright Canada Montréal, Quebec   For The Appellant Nathalie G. ...