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Canada, 2012 DTC 5031 [at at 6682], 2011 FCA 355       Federal Court of Appeal Cour d'appel fédérale   Date: 20111215 Docket: A-222-11   Citation: 2011 FCA 355   CORAM:       EVANS J.A.                            ... (Jentel), is entitled to scientific research and experimental development tax credits (SRED credits) under the Income Tax Act, R.S.C. 1985, c. 1 (5th Supp.), as amended (the Act) in relation to its 2005 fiscal year. ... During its 2005 fiscal year, Jentel set out to overhaul its Multi-Bins concept. ...

LAYDEN-STEVENSON J.A.                         TRUDEL J.A.   BETWEEN: HER MAJESTY THE QUEEN Appellant   and     STANTEC INC. ...   [3]                In 2005, Stantec incurred costs in Canada to obtain a listing of its shares on the New York Stock Exchange. ...   [18]            The appeal will be dismissed with costs.       J.A.     ...

MONAGHAN J.A.   BETWEEN:     Docket: A-199-21     MAGREN HOLDINGS LTD.     ... Appellant     and     HIS MAJESTY THE KING     Respondent     AND BETWEEN:     Docket: A-201-21     MAGREN HOLDINGS LTD. ... Canada, 2005 SCC 54, [2005] 2 S.C.R. 601 at para. 66 [Canada Trustco]; Copthorne Holdings Ltd. v. ...

The Queen, 2005 TCC 806, [2006] 2 C.T.C. 2045. While Coast Capital acknowledges that the Nunn decision was reversed on appeal (2006 FCA 403, 367 N.R. 108 [Nunn FCA]), it says that this Court did not do so on the basis that only the Minister can rely on the sham doctrine. ... HER MAJESTY THE QUEEN   PLACE OF HEARING: Vancouver, British Columbia   DATE OF HEARING: April 19, 2016   REASONS FOR JUDGMENT BY: GLEASON J.A.   ... RENNIE J.A.   DATED: June 15, 2016   APPEARANCES: Robert Kopstein Alexandra Brown   For The Appellant   Perry Derksen   For The Respondent   SOLICITORS OF RECORD: Blake, Cassels & Graydon LLP Barristers and Solicitors Vancouver, British Columbia   For The Appellant   William F. ...

Canada, 2005 SCC 54 at para. 10 and Placer Dome Canada Ltd. v. Ontario (Minister of Finance), 2006 SCC 20 at para. 22). ... MARIA CSAK     PLACE OF HEARING: Toronto, Ontario   DATE OF HEARING: January 21, 2025   REASONS FOR JUDGMENT BY: BIRINGER J.A.   ... PAMEL J.A.   DATED: MARCH 14, 2025   APPEARANCES: Meaghan Mahadeo Grace Jothiraj   For The Appellant   John Buote   For The Respondent   SOLICITORS OF RECORD: Shalene Curtis-Micallef Deputy Attorney General of Canada   For The Appellant   BRS Tax Lawyers LLP Toronto, Ontario   For The Respondent     ...

LASKIN J.A.   BETWEEN:     SHER-E PUNJAB RADIO BROADCASTING INC.     Appellant     and     HER MAJESTY THE QUEEN     Respondent   Heard by online video conference hosted by the registry on October 6, 2020. ... I.   Background [3]   Sher-E-Punjab Radio failed to file its corporate tax returns for its 2005 to 2012 taxation years. ... He was the officer and director of Sher-E-Punjab Radio who would have been responsible for filing its corporate tax returns for its taxation years from 2005 to 2012. ...

LASKIN J.A.   BETWEEN:     MINISTER OF NATIONAL REVENUE     Appellant     and     CAMECO CORPORATION     Respondent   Heard at Toronto, Ontario, on November 28, 2018. ... R., 2005 SCC 54 at para. 44, [2005] 2 S.C.R. 601). The standard of review applicable to the applications judge’s interpretation of paragraph 231.1(1)(a) is therefore correctness: Housen v. ... Canada (Customs & Revenue Agency), 2005 FCA 218 at para. 11 (Saipem), leave to appeal refused, 349 N.R. 200 (S.C.C.). ...

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  (CanLII),  [2005] 3 S.C.R. 141  at para. 10; [I have omitted the reference to Canada Trustco Mortgage Co. v. Canada, 2005 SCC 54, at para. 47 as the paragraph cited addresses the distinct and particularized application of the General Anti-Avoidance Rule under section 245 of the Income Tax Act, R.S.C., 1985, c.1 (5 th Supp.).] [28]   Adopting this approach, an ambiguity does arise from a broader examination of the ETA as to how subsections 132(3) and 150(1) interact. ... HER MAJESTY THE QUEEN     PLACE OF HEARING: Toronto, Ontario   DATE OF HEARING: March 21, 2019   REASONS FOR JUDGMENT BY: NOËL C.J.   ...

GOYETTE J.A.     BETWEEN:     PRESIDENT ’ S CHOICE BANK     Appellant     and     HIS MAJESTY THE KING     Respondent   Heard at Toronto, Ontario, on March 6, 2024. ... GOYETTE J.A.     BETWEEN:     PRESIDENT’S CHOICE BANK     Appellant     and     HIS MAJESTY THE KING     Respondent   REASONS FOR JUDGMENT GOYETTE J.A. ... Canada, 2005 SCC 54, at para. 10). The interpretation issue is focused on the following phrase in subsection 181(5) of the ETA: … a particular person at any time pays, in the course of a commercial activity of the particular person, an amount to the supplier for the redemption of the coupon … [92] This text, which focuses on the payment of an amount in the course of a commercial activity, is unique to subsection 181(5) of the ETA. ...

(the ITA) with regard to a dividend (Dividend B) that it had received from a deposit insurance corporation during its 2005 taxation year. ... However, from 1989 until 2005, CUDIC and STAB jointly levied and maintained this fund, with the FI Commission’s knowledge and consent. ... Canada, 2005 SCC 54, [2005] 2 S.C.R. 601 at paragraph 10 [Canada Trustco]). ...