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RENNIE J.A.   BETWEEN:     CANADIAN IMPERIAL BANK OF COMMERCE     Appellant     and     HER MAJESTY THE QUEEN     Respondent   Heard by online video conference hosted by the registry on February 16, 2021. ... RENNIE J.A.   BETWEEN:     CANADIAN IMPERIAL BANK OF COMMERCE     Appellant     and     HER MAJESTY THE QUEEN     Respondent   PUBLIC REASONS FOR JUDGMENT WEBB J.A. [1] The Canadian Imperial Bank of Commerce (CIBC) made substantial payments to Aeroplan Limited Partnership (Aeroplan) under the agreement between these companies related to the Aeroplan credit cards issued by CIBC. ... Canada, 2005 FCA 252, 257 D.L.R. (4th) 1, noted: [31] In an appeal against an assessment under the Act, the outcome does not belong to the parties. ...

Canada (Attorney General), 2005 SCC 25, [2005] 1 S.C.R. 401, at paras. 55-56 and 69-70; Salomon v. ... A fair reading of his reasons reflects the focus on the allocation of the income of AIGLP and the losses of the GERI partnership. [50] The only partners of the GERI partnership, as set out in paragraph 99 of the Partial Agreed Statement of Facts and Schedule “A” to that agreement, were: ● Elisa Aquilini ● Francesco Aquilini ● Roberto Aquilini ● Paolo Aquilini ● Global Coin Corporation ● Cranberry Plantation Inc. [51] None of the EAFT, the FAFT, the RAFT, or the PAFT were partners of the GERI partnership. ... François Daigle Deputy Attorney General of Canada For The Respondent   ...

THE ESTATE OF PASQUALE PALETTA     PLACE OF HEARING: TORONTO, ONTARIO   DATE OF HEARING: APRIL 4, 2022   REASONS FOR JUDGMENT BY: NOËL C.J.   ... LASKIN J.A.   DATED: May 17, 2022   APPEARANCES: Justice Malone Dina Elleithy   For The Appellant   Justin Kutyan Kelly Ng   For The Respondent   SOLICITORS OF RECORD: A. François Daigle Deputy Attorney General of Canada Ottawa, Ontario   For The Appellant   KPMG Law LLP Barristers and Solicitors Toronto, Ontario For The Respondent     ...

EVANS J.A.   STRATAS J.A.       BETWEEN: HER MAJESTY THE QUEEN Appellant and J. ... Canada, [2005] 2 S.C.R. 601, 2005 SCC 54 at para. 10, the Supreme Court of Canada prescribed the proper approach for interpreting taxation statutes: …The interpretation of a statutory provision must be made according to a textual, contextual and purposive analysis to find a meaning that is harmonious with the Act as a whole.  ... “David Stratas” J.A.       “I agree   M. Nadon J.A.”   “I agree   John M. ...

Mr Green, a unionized employee, commenced work for the TTC on October 18, 1979, and became disabled in 2005. His last day of work was June 18, 2005, and he qualified for long-term benefits under the union plan on April 14, 2006. ... Evans” J.A.   “I agree             M. Nadon J.A.”   “I agree             David Stratas J.A.”     ...

R., 2004 TCC 727, 2005 D.T.C. 62. As far as I am aware, the Tax Court was not referred to these decisions. ... Canada (Attorney General), 2005 FCA 143, 337 N.R. 255: [10] For a sound, proper and orderly administration of justice, a question going to the jurisdiction of the Court to adjudicate can always be raised. [48]   Telus instructs that a jurisdictional issue can be raised at any time, but this does not mean that the issue can be raised in a manner that may be prejudicial to the other party. ... Kroft   For The Respondent   SOLICITORS OF RECORD: Nathalie G. Drouin Deputy Attorney General of Canada   For The Appellant   Bennett Jones LLP Vancouver, British Columbia   For The Respondent     ...

Specifically, she says that she has a letter of resignation effective December 31, 2002, and a publicly available document prepared by the Corporation containing a list of directors as of 2005 or 2006, a list on which her name does not appear. ... Madison may present any documentary evidence that is not in the current record, including her letter of resignation and the Corporation’s 2005 or 2006 list of directors. ... Sharlow” J.A.   “I agree           Eleanor R. Dawson J.A.”   “I agree           Johanne Trudel J.A.”     ...

Subsection 220(3.1) was amended in 2005, limiting the period for which interest relief can be granted to ten years. Because the appellants’ requests were filed prior to 2005, the appellants were not restricted as to the period for which the Minister could grant interest relief. ... LOCKE J.A.   DATED: DECEMBER 30, 2020   APPEARANCES: Howard Winkler   For The Appellants   Andrea Jackett For The Respondents   SOLICITORS OF RECORD: Winkler Law Toronto, Ontario   For The Appellants   Nathalie G. ...

GLEASON J.A.     Docket: A-171-17 BETWEEN:   MADISON PACIFIC PROPERTIES INC. ... Canada, 2005 SCC 54, [2005] 2 S.C.R. 601 at para. 44, the “textual, contextual and purposive interpretation of specific provisions of the Income Tax Act” for the purpose of discerning their underlying policy is “essentially a question of law”. ... HER MAJESTY THE QUEEN     PLACE OF HEARING: Vancouver, British Columbia   DATE OF HEARING: November 7, 2018   REASONS FOR JUDGMENT BY: GLEASON J.A.   ...

Nash, 2005 FCA 386 (Rothstein J.A.), leave to appeal to SCC refused, 31291 (20 April 2006) [Nash] and Klotz v. Canada, 2005 FCA 158 (Sexton J.A.), leave to appeal to SCC refused, 30981 (20 April 2006) [Klotz]. [10]   Nash and Klotz involved similar, though not identical, “art-flipping schemes” (a term used by CCRA in their news release of November 15, 2002, AB page 1674). ... Drouin Deputy Attorney General of Canada   For The Respondent     ...