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NADON J.A.                         MAINVILLE J.A.   BETWEEN: MICHEL TREMBLAY Appellant and MINISTER OF NATIONAL REVENUE Respondent                 Hearing held at Québec, Quebec, on January 12, 2011. ... Ruest, who claims that the market conditions in 2002, 2004 and even 2005 were the same as in 1999. ... Canada, [2005] 1 S.C.R. 401, at page 421; Nash v. Canada, [2005] F.C.J. ...

Canada, 2005 SCC 54 (Canada Trustco) and Lipson v. Canada, 2009 SCC 1. ...   [20]            The appellant also takes issue with the Tax Court judge’s reliance on the 2005 amendment to the definition of “affiliated persons” at section 251.1 of the Act. ...   [36]            Of significance for our purpose is the amendment to the definition of “affiliated persons” in 2005 to include trusts. ...

Singh Lyn Ragonetti Bindal LLP, 2005 FC 1538 at paragraph 18; Canada (Minister of National Revenue – M.N.R.) v. ... "Johanne Trudel" J.A.         “I agree            J.D. Denis Pelletier J.A.”   “I agree            Robert M. Mainville J.A.”         ANNEX   (Ms. Maria Van Dyk’s sworn affidavit of June 21, 2012)     8.         […]   (a)        N/A   (b)        N/A   (c)        Personal Expenses: the [appellant] provided insufficient information. ...

Canada, 2005 SCC 54, at paragraph 47: [i]n order to reveal or resolve any latent ambiguities in the meaning of provisions of the Income Tax Act, the courts must undertake a unified textual, contextual and purposive approach to statutory interpretation. ... In this regard, I need only take judicial notice of the 2007-2008 global downturn and the fact that despite this downturn, the Reference Assets actually grew in value from $1,546,000,000 at December 31, 2005 to $1,655,000,000 and $1,718,000,000 at December 31, 2008 and 2009 respectively (Financial Statements of SLT for the years ended December 2005 and 2009, Appeal Book, respectively Vol. 4, p. 790 and Vol. 5, p. 809). [49]   During the hearing, counsel for the appellant alluded to the Lehman Brothers bankruptcy in 2008 and argued that the issuing banks could have suffered the same fate. ... Canada, 2005 SCC 54, [2005] 2 S.C.R. 601 [Canada Trustco]). [55]   In contrast with the word “partnership” which has a well-defined legislative meaning under provincial law (as does for instance the word “share” in paragraph 94.1(1)(a)), there is no single meaning of the word debt; it is capable of various definitions and the one which best reflects Parliament’s intent can only be made apparent by a textual, contextual and purposive analysis of paragraph 94.1(1)(a) (Canada Trustco, para. 10; Canada v. ...

As a result, he received no Notices of Assessment prior to 2005 for the 1997 to 2003 taxation years. ... Connolly contributed $15,000 to his RRSP and $15,000 to a spousal RRSP; he contributed a further $15,000 to his spousal RRSP in 2004. [6]   In early 2005, Mr. ... Connolly for the 2005 to 2008 taxation years. Over several years, Mr. ...

International Association of Bridge, Structural, Ornamental and Reinforcing Iron Workers, Local 771, 2005 SCC 70, [2005] 3 S.C.R. 425, at paragraph 28). ... This decision was affirmed on appeal in a brief endorsement (2005 CanLII 1402, [2005] O.J. ... Drouin Deputy Attorney General of Canada   For The Respondent   Chaitons LLP Toronto, Ontario For The Intervener     ...

Pomerleau or the appellant) 2005 taxation year. [2]   This reassessment was issued pursuant to the general anti-avoidance rule (GAAR) provided for in section 245 of the Income Tax Act, R.S.C. 1985, c. 1 (5th Supp.) ... Canada, 2005 SCC 54, [2005] 2 S.C.R. 601 [Trustco], paragraphs 18, 21 and 36). [55]   The appellant acknowledges that the receipt of the amount of $994,628 on a tax-free basis upon the redemption by Gestion of its Class C shares constitutes a tax benefit and that this benefit was achieved by entering into avoidance transactions. ... Drouin Deputy Attorney General of Canada   FOR THE RESPONDENT     ...

BETWEEN: CHERYL ALISON LANS Appellant and   ATTORNEY GENERAL (CANADA REVENUE AGENCY) Respondent     REASONS FOR ORDER SHARLOW J.A. [1]                The appellant Cheryl Alison Lans has appealed the judgment of the Tax Court of Canada dismissing her appeal of assessments made under the Income Tax Act, R.S.C. 1985, c. 1 (5 th Supp.) for the 2004 and 2005 taxation years (2011 TCC 121). ...   [3]                Ms. Lans filed a notice of appeal. Her grounds of appeal read as follows: I do not believe that I was negligent or that the CRA can prove that I was, therefore their reassessment of November 30, 2009 for the years 2004 and 2005 was too late, and in error in any case since my RRSP over-contributions were made in 2003 and 2004, not in 2005. ... I want the Court to dismiss the taxes, late-filing penalties and arrears interest on my RRSP over contributions for the years 2004 and 2005 due to the unfairness and perhaps malice with which they were imposed and due to the financial hardship that they would impose on me.       ...

CONCURRED IN BY:   DE MONTIGNY C.J.   HECKMAN J.A.         Date: 20240307     Docket: A-201-22 Citation: 2024 FCA 42   CORAM:   DE MONTIGNY C.J.   ... Canada, 2005 SCC 54 at para. 44 [Canada Trustco]; Housen v Nikolaisen, 2002 SCC 33 at paras. 8, 26–37 [Housen]. ... HIS MAJESTY THE KING     PLACE OF HEARING:   Montréal, Quebec       DATE OF HEARING:   November 15, 2023       REASONS FOR JUDGMENT BY:   GOYETTE J.A.       ...

BETWEEN: DENIS LANNO Appellant and CANADA CUSTOMS AND REVENUE AGENCY Respondent REASONS FOR ORDER SHARLOW J.A. [1]                On May 2, 2005, in the decision of Lanno v. Canada (Customs and Revnue Agency), 2005 FCA 153, this Court allowed Mr. ... Lanno is of the view that the Minister has not complied with this Court's May 2, 2005 decision, his remedy should be pursued in the Federal Court. [12]            I would dismiss this motion with costs. ...