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TCC
675869 BC Ltd op Lexington Tire Superstore v. M.N.R., 2007 TCC 301
Signed at Ottawa, Canada, this 18th day of May, 2007. “M.A. Mogan” Mogan D.J. ... The basic is sue is whether those 90 individuals were, during certain periods in 2003, 2004 and 2005, employees of a corporate Appellant or independent contractors. ... [5] As an example of a worker agreement in Exhibit A-1, I will set out the terms of the agreement between Katona Tires and Arif Roya dated April 8, 2005. ...
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 ...
TCC
Louie v. The Queen, 2018 TCC 225, rev'd in part on "advantage" issue (for subsequent years) 2019 FCA 255
Wilhelm JUDGMENT The appeal with respect to the 2009 taxation year is dismissed. ... Canada, 2005 SCC 54, [2005] 2 S.C.R. 601, at paragraph 26, elaborated that the term should be “read not in the sense of actual knowledge but in the broader sense of ‘because of’ or ‘in relation to’ the series” (this interpretation was confirmed in Copthorne, paragraphs 55-56). ... Wilhelm COUNSEL OF RECORD: For the Appellant: Name: Alan Louie Firm: For the Respondent: Nathalie G. ...
TCC
Coady v. The Queen, 2006 TCC 153
.____________________________________________________________________ Appeal heard on April 26 and 27, 2005, at Charlottetown, Prince Edward Island, By: The Honourable Justice A.A. ... A. Yeah. Q. Now, you didn't do that, did you? A. ... Coady and Her Majesty the Queen PLACE OF HEARING: Charlottetown, Prince Edward Island DATE OF HEARING: April 26 and 27, 2005 REASONS FOR JUDGMENT BY: The Honourable Justice A.A. ...
TCC
Hong Kong Style Café Ltd. v. The Queen, 2022 TCC 9
Under section 163(2) of the Income Tax Act, RSC 1985, c.1, as amended the (“ ITA ”) and under section 285 of the Excise Tax Act, RSC 1985, c.E-15, as amended (the “ ETA ”), penalties were also imposed. ... McDougall, 2008 SCC 53 (“ McDougall ”) and Merck Frosst Canada Ltd. v. ... Canada, 2005 FCA 104 at paragraphs 34 – 35. [40] Income Tax Act, RSC 1985, c 1 (5th Supp), s 152(4)(a)(i) [ITA]. [41] Naguib v. ...
TCC
Clarke v. M.N.R., 2009 TCC 417
Signed at Ottawa, Canada this 1st day of September, 2009. “G. ... Canada, [2005] T.C.J. No. 266. [2] Exhibit A-1. [3] Exhibit A-2. ...
TCC
Encore Cellular Inc. v. The King, 2024 TCC 35
They are: (i) Whether the Minister correctly assessed additional GST/HST payable by the appellant; (ii) Whether the Minister correctly disallowed specific Input Tax Credits (“ ITCs ”) claimed; (iii) Whether the appellant is liable for a penalty pursuant to s. 285 of the Excise Tax Act (the “ Act ”) [1], and (iv) Whether the Minister was correct in relying upon ss. 298(4) of the Act, to reassess the statute-barred reporting periods ending on April 30, 2010 and April 30, 2011 (the “ Statute-Barred Periods ”). [2] II. FACTS [4] The appellant is a GST registrant, having been registered for GST since May 26, 2005. ... He obtained an education in Business studies in both Germany and Canada. [24] He opened Encore Cellular in 2005. ...
TCC
Knapik v. The Queen, 2006 TCC 375 (Informal Procedure)
They read: 9. On filing his income tax return for the 2003 year, the Appellant claimed a deduction for moving expenses of $9,420.44 as follows: Moving Costs $ 839.95 Legal Fees for New Residence $ 214.00 CMHC Fee $8,366.49 Total Moving Expenses Claimed $9,420.44 10. ... The Notice of Objection for the 2003 year was filed March 9, 2005. 13. ... C. STATUTORY PROVISIONS, GROUNDS RELIED ON AND RELIEF SOUGHT 16. ...
TCC
Dugas v. M.N.R., 2006 TCC 527
., 2006 TCC 527 Docket: 2006-609(EI) BETWEEN: SYLVIE DUGAS, Appellant, and THE MINISTER OF NATIONAL REVENUE, Respon dent. ... [17] She appeared before an investigator working for Human Resources Canada and signed a declaration dated February 8, 2005. ... The Worker was laid off when the Payor had fewer contracts. I reread the Worker’s statutory declaration of February 8, 2005, to her. ...
TCC
McDermid v. The Queen, 2014 DTC 1191 [at 3724], 2014 TCC 264 (Informal Procedure)
(See also Bowman C.J. in McNaughton v The Queen, 2005 TCC 714, at para. 9.) [23] Mr. ... Woods DATE OF JUDGMENT: September 3, 2014 APPEARANCES: Agent for the Appellant: Scott McDermid Counsel for the Respondent: Kristian DeJong Amandeep Sandhu COUNSEL OF RECORD: For the Appellant: Name: N/A Firm: For the Respondent: William F. Pentney Deputy Attorney General of Canada Ottawa, Ontario ...