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TCC

Williams v. The Queen, 2008 TCC 418 (Informal Procedure)

The Queen, 2008 TCC 418 (Informal Procedure)         Citation: 2008 TCC 418 Date: 20080722 Docket: 2007-3396(IT)I   BETWEEN:   EYVONE WILLIAMS,   Appellant, and   HER MAJESTY THE QUEEN,   Respondent.     ... He testified that the Appellant made a request to ManuLife in June 2005 to have the payment classified as an insurance benefit rather than taxable income as per the T4A slip which had been issued ... Walcott       Counsel for the Respondent:   Kandia Aird   COUNSEL OF RECORD:   For the Appellant:   Name:     Firm:     For the Respondent: John H. ...
TCC

Mailloux c. La Reine, 2007 TCC 711 (Informal Procedure)

Signed at Ottawa, Canada, this 3rd day of Decem b er 2007.     “Alain Tardif” Tardif J.     ... FURTHER TO THE NOTICES OF OBJECTION DATED MARCH 12, 2005, SENT TO THE SHAWINIGAN TAXATION CENTRE FOR THE YEARS 2000, 2001, 2002 AND 2003, THE RESPONSE TO WHICH I RECEIVED ON DECEMBER 27, 2006, FROM THE LAVAL OFFICE, APPEALS DIVISION.   ... Signed at Ottawa, Canada, this 3rd day of December 2007.       “Alain Tardif” Tardif J.           ...
TCC

Salisbury House of Canada Ltd. et al. v. The Queen, 2013 TCC 236

Roitman was reassessed in accordance with the terms of the settlement agreement on January 24, 2005. ... Roitman filed no objection to the reassessment.   8     On June 15, 2005, Mr. ... The damages sought are "damages for misfeasance in public office", "special damages, including costs of defending the proposed income tax assessments and in prosecuting the civil income tax appeal" and "punitive, exemplary and aggravated damages".   10     On August 2, 2005, the Crown filed a Statement of Defence.   11     On August 26, 2005, the Crown filed a motion pursuant to Rule 221 of the Federal Court Rules, 1998 (the "Rules") on the ground that the Statement of Claim was immaterial, redundant, scandalous, frivolous and vexatious, and was otherwise an abuse of the process of the Court. ...
TCC

Kam v. The Queen, 2013 DTC 1218 [at at 1210], 2013 TCC 266 (Informal Procedure)

Signed at Ottawa, Canada, this 28th day of August 2013.     “Réal Favreau” Favreau J.           ...   [5]              The Appellant’s 2004 and 2006 income tax returns were initially assessed on April 18, 2005 and October 22, 2007 (the “Assessments”). ... Signed at Ottawa, Cana da, this 28th day of August 2013.       “Réal Favreau” Favreau J.   ...
TCC

Arciresi v. The Queen, 2014 DTC 1037 [at at 2714], 2013 TCC 331 (Informal Procedure)

Signed at Ottawa, Canada, this 22nd day of October 2013.     “Réal Favreau” Favreau J.     ... [OFFICIAL ENGLISH TRANSLATION]     REASONS FOR JUDGMENT     Favreau J. ...   [15]         For these reasons, the appeal is dismissed.     Signed at Ottawa, Canada, this 22nd day of October 2013.     ...
TCC

General Motors of Canada Limited v. The Queen, [2008] GSTC 41, 2008 TCC 117, aff'd [2009] GSTC 64, 2009 FCA 114

Signed at Ottawa, Canada, this 22nd day of February 2008.       “Diane Campbell” Campbell J.         ... The Queen, 2005 DTC 821 (T.C.C.) at paragraph 8, Rip J. as he was then, stated:   Pleadings fulfil several functions. ... , GST & Commodity Tax (Carswell) Vol. XIII, No. 4 (May 1999), pp 25-27; Finance’s Technical Notes (July 1997). [2] “Claiming an ITC in the Course of Commercial Activity”, 2005 Commodity Tax Symposium (CICA) at pp 11-12. ...
TCC

Davis v. The Queen, 2008 TCC 31

  [27]     Exhibit A-9 reads as follows:   Employee   No. of Canfish Shares         Greg Allen   30.5   Ross Avery   242   Brad Boles   242   Reid Conrad   30.5   Tom Curtis   363.5   Rob Doyle   30.5   Harold Fitz   182   Rick Gronvall   515   Lee Hearn   303   Layne Holmwood   106   Doug Hunter   91   Bill Jenkins   30.5   Claude Kendall   606   Matt Jordan   15   Chris LaFleur   30.5   Ken Leslie   72.5   Troy Leslie   48   Joe Marshall   30.5   Blain McCallum   30.5   Dave McCormick   151.5   John McElroy   606   Colin MacPherson   15   Dan MacNeil   60.5   Ed Malm   30.5   Glenn Schultz   30.5   Dave Shubert   30.5   Kim Tolchard   30.5   Greg Venus   91   Hazel Yates   30.5   Darrell Wolter   15   Karl Beagrie   303   Darcy Ramsay   303   Scott Davis   303           Total   5000     [28]     Counsel for the Appellants stated that the proceeds from the sale of the 5% of the Canfish shares were paid to an entity called “SKD Holdings Inc.”. ... (Toronto: Irwin Law Inc., 2005) at 39. [2] Ibid at 41. [3] Supra note 2 at 43. [4] (L.Q., 1991, c. 64). [5] Michael N. Kandev & Fred Purkey, “Practical Application of Trusts,” Reports of Proceedings of Fifty-Sixth Tax Conference, 2004 Tax Conference (Toronto: Canadian Tax Foundation, 2005) at p. 5 and 6. ...
TCC

McGrath v. The Queen, 2007 DTC 894, 2007 TCC 295 (Informal Procedure)

The Queen, 2007 DTC 894, 2007 TCC 295 (Informal Procedure)         Citation: 2007TCC295 Date: 20070528 Docket: 2006-1383(IT)I BETWEEN: SUSAN McGRATH, Appellant, and   HER MAJESTY THE QUEEN, Respondent.     ... It is dated June 30, 2005 and reads in part:   On behalf of the executive of the Elementary Teacher's Federation of Ontario, I wish to extend my personal congratulations to you for having been selected as a recipient of the Master's Scholarship Women's Program. ... Signed at Ottawa, Canada, this 28th day of May, 2007.       “C.H. McArthur” McArthur J.     ...
TCC

Leclerc v. The Queen, 2010 DTC 1209 [at at 3556], 2010 TCC 99 (Informal Procedure)

[OFFICIAL ENGLISH TRANSLATION]     AMENDED REASONS FOR JUDGMENT   Favreau J ... Canada, [2005] 2 S.C.R. 601, "[t]he 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" (page 601) ...   [22]          For these reasons, the appeals are dismissed.     Signed at Ottawa, Canada, on this 9th day of March 2010.       ...
TCC

101139810 Saskatchewan Ltd. v. The Queen, 2017 TCC 3

As stated by the Supreme Court of Canada in Canada Trustco Mortgage Co. v R, 2005 SCC 54, [2005] 2 SCR 601 at paragraph 10: It has long been 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”…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. ... Subsection 55(2) opens with the words a corporation and subsequently in paragraph (a) states shall be deemed not to be a dividend received by the corporation ”. ... Pentney Deputy Attorney General of Canada Ottawa, Canada     ...

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