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Canada (Customs and Revenue Agency), 2005 FCA 153 at paragraph 6, “[t]he granting of relief is discretionary, and cannot be claimed as of right ...   – III –   [62]            Following that methodology, the Delegate proceeded to assess the state of the law ... DATED:                                                                                 October 24, 2012     APPEARANCES:   Brooke Sittler Jamie Hammersmith   FOR THE APPELLANT   Joe Aiello Bruce Gammon FOR THE RESPONDENTS         SOLICITORS OF RECORD:   Myles J. ...

R. (2004 FCA 403, 247 D.L.R. (4 th) 597) (leave to appeal to the Supreme Court of Canada dismissed ([2005] S.C.C.A. ... HER MAJESTY THE QUEEN     PLACE OF HEARING: Vancouver, British Columbia   DATE OF HEARING: November 27, 2014   REASONS FOR JUDGMENT BY: WEBB J.A.   ... BOIVIN J.A.   DATED: February 23, 2015   APPEARANCES: Allistair G. Campbell Michelle Moriartey   For The Appellant   David Everett Melissa Nicolls   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     ...

BWS and Keybrand are active in the restaurant and food service industry. [5]   In 2005, one of Mr. ... Strassburger that they should invest in Vidabode, which was a Nova Scotia company that was incorporated in 2005. ... Between 2005 (its first year of operation) and 2009 (its last year prior to the share purchase in issue), Vidabode incurred the following losses: Year Ending Net Loss December 31, 2005 ($152,091) December 31, 2006 ($443,407) December 31, 2007 (restated) ($1,116,253) December 31, 2008 ($7,117,929) December 31, 2009 ($8,622,524) Total:   =sum(B2:B6) ($17,452,204) [9]   The financial statements for the year ended December 31, 2009 indicate that the accumulated deficit, as of that time, was $17,708,743. ...

WOODS J.A.     BETWEEN: THANH TRUC TRUONG Appellant and HER MAJESTY THE QUEEN Respondent Heard at Toronto, Ontario, on January 11, 2018. ... This is acknowledged to be a very rough assessment tool, but its use is justified in this case by the appellant’s failure to keep proper records as required by the relevant legislation. [3]                The assessments under the Income Tax Act added to income an aggregate amount of $1,682,509 for the 2005 to 2009 taxation years, inclusive. ... Drouin Deputy Attorney General of Canada For The Respondent       ...

Canada, 2005 SCC 54 at para. 10, [2005] 2 S.C.R. 601). [29]            In my view, the Tax Court erred in concluding that the term “credit” in subsection 232(1) takes its meaning from the commercial terms “credit note” and “credit memorandum.” ... LASKIN J.A.   DATED: JANUARY 12, 2018   APPEARANCES: David J. Thompson   For The Appellant   Suzanie Chua   For The Respondent   SOLICITORS OF RECORD: David J. ... Barrie, Ontario   For The Appellant   Nathalie G. Drouin Deputy Attorney General of Canada   For The Respondent     ...

Canada Trustco Mortgage Company, 2005 SCC 54, 2005 D.T.C. 5523 (Canada Trustco), has given us this guidance: [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. ... THE MINISTER OF NATIONAL REVENUE     PLACE OF HEARING: toronto, Ontario   DATE OF HEARING: February 10, 2016   REASONS FOR JUDGMENT BY: WEBB J.A.   ... Pentney Deputy Attorney General of Canada For The Respondent     ...

Ralph Misener (Ship), 2005 FCA 139 at para. 13). Jurisdictional issue [23]            The appellants focus on the effect of the decision of the Federal Court judge, as upheld by this Court, giving effect to the arbitration clause and holding that the Federal Court had no jurisdiction over the respondent’s action. ... Spiro   For The Appellants   André Lespérance     For The Respondent   Bruce W. ... Montréal, Quebec   For The Respondent   TRUDEL & JOHNSTON Montréal, Quebec   For The Respondent       ...

In a separate proceeding a further fine of $101,398.80 was imposed for tax evasion relating to the 2000 through 2005 taxation years. [7]                The appellant now argues that because evidence obtained during the investigation of his criminal tax evasion was used to obtain the jeopardy order, amounts collected under that order should first be applied to pay his criminal fines. ... HER MAJESTY THE QUEEN   PLACE OF HEARING: Vancouver, British Columbia   DATE OF HEARING: June 10, 2014   REASONS FOR JUDGMENT BY: DAWSON J.A.   ... Victoria, British Columbia   for the appellant   William F. Pentney Deputy Attorney General of Canada For The Respondent   ...

The judge writes that Kosma-Kare, despite the warning it received from the ARQ in 2005, agreed to work with people with no concern as to whether they had work permits or a social insurance number, thinking that the blame would be placed on the agencies with which it was working. ... SCOTT J.A.   DELIVERED FROM THE BENCH BY: GAUTHIER J.A.   APPEARANCES: Louis-Frédérick Côté   FOR THE APPELLANT   Martine Bergeron   FOR THE RESPONDENT   SOLICITORS OF RECORD: Spiegel Sohmer Inc. Montréal, Quebec   FOR THE APPELLANT   Larivière Meunier Montréal, Quebec   FOR THE RESPONDENT     ...

Prince of proposed reassessments for the 2005 to 2014 taxation years. ... Canada (Minister of National Revenue), 2005 FC 639 at paras. 8-9). [17]   Second, to accede to the appellant’s argument would, effectively nullify or over-ride the power granted to the Minister under subsection 152(4) of the Income Tax Act to reassess “at any time”. ... MINISTER OF NATIONAL REVENUE AND CANADA REVENUE AGENCY     PLACE OF HEARING: Montréal, Quebec   DATE OF HEARING: JANUARY 22, 2020   REASONS FOR JUDGMENT BY: RENNIE J.A.   ...