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The Minister of National Revenue seems to have accepted this reversal. [3]      Two or three central facts may be taken as admitted:            (a)      The appellant in 2000 and 2001 bought and sold shares;            (b)    He sustained losses of $19,799 and $117,461 in 2000 and 2001 respectively.            ... Paragraph 9 reads as follows: 9.          In assessing tax and in confirming the assessment for the 2003 taxation year, the Minister assumed the same facts, as follows:            (a)       in the 2000 taxation year, the Appellant incurred non-capital losses of $22,196;            (b)      non-capital losses of other years were deducted from the Appellant's reported income for the 2001 and 2002 taxation years in the amounts of $10,000 and $12,196 respectively;            (c)       the Appellant's taxable income for the 2002 taxation year, after the deduction of non-capital losses of other years, amounted to $47,136;            (d)      the Appellant does not have available non-capital losses of other years to deduct from his income for the 2003 taxation year. [6]      This is a totally inadequate pleading. ... The Queen, 2004 DTC 3090 (TCC) aff'd, 2005 DTC 5607 (FCA); McGroarty v. ...

      « François Angers » Angers J.       Citation: 2007TCC305 Date: 20070622 Dockets: 2006-835(IT)G 2006-836(IT)G 2006-837(IT)G 2006-838(IT)G 2006-839(IT)G   BETWEEN:   HER MAJESTY THE QUEEN, Applicant, and   COMTAX COMMODITY TAX CONSULTANTS INC., JACKY SCHRYVER, Respondents.     ... The Queen, 2004 DTC 2923 (T.C.C.) and 2005 DTC 5211 (F.C.A.); and Telus Communications (Edmonton) Inc. v. ...   [37]     The respondents are entitled to costs which I fix at $1,000.     ...

Body____________________________________________________________________ JUDGMENT           The appeal from the assessment made under the Excise Tax Act, notice of which is dated January 28, 2005, for the reporting period ending December 31, 2002, is dismissed. ... CITATION:                                        2007TCC69 COURT FILE NO.:                             2005-4300(GST)I STYLE OF CAUSE:                           SAMUEL C. ... Body COUNSEL OF RECORD:        For the Appellant:                           Name:                       N/A                             Firm:                      N/A        For the Respondent:                     John H. ...

R., [2005] G.S.T.C. 199, cautioned the Court from broadening the scope of de facto directors. ... Signed at Ottawa, Canada, this 20th day of October 2014.       “E.P. Rossiter” Rossiter A.C.J.   ... Pentney Deputy Attorney General of Canada Ottawa, Canada     ...

The Queen, 2005 TCC 126 (“Seni”), the taxpayer had built and sold three homes over a three-year period. ... Smith” Smith J.   CITATION: 2022 TCC 91   COURT FILE NO.: 2020-973(GST)I   STYLES OF CAUSE: COREY LIBFELD v. ... Smith DATE OF JUDGMENT: August 12, 2022   APPEARANCES: Counsel for the Appellant: Angelo Gentile Monica Carinci   Counsel for the Respondent: Natasha Mukhtar COUNSEL OF RECORD: For the Appellant: Angelo Gentile Monica Carinci   Firm: Aird & Berlis LLP   For the Respondent: François Daigle Deputy Attorney General of Canada Ottawa, Canada     ...

Thus, while the employer permitted the appellant to pay the Amount, the appellant was not required by his employer to pay it as mandated by subparagraphs 8(1)(f)(i) and 8(1)(h)(ii). [32]         In Karda v Canada, 2005 TCC 564, 2005 DTC 1375, the court found that it may have been a smart economic decision for the employee to voluntarily incur car employment expenses to improve his bonus and create additional income, but under the ordinary meaning of subparagraph 8(1)(f)(i), he was not required to pay for such expenses. ...   [13]           Except for section 67.1.   [14]          Exhibit R-7. ...   [15]          Exhibit R-7.   [16]          Agreement – Clauses B.1. and B.2 ...

His duties included:        i.             answering phone calls;      ii.             ... ordering materials;   iv.             building walkways, planters, retaining walls and various other brick work;      v.             ... Pentney Deputy Attorney General of Canada Ottawa, Canada     ...

“Gabrielle St-Hilaire” St-Hilaire J.   Citation: 2023 TCC 37 Date: 20230330 Docket: 2021-1804(IT)I BETWEEN: 3792391 CANADA INC., Appellant, and HIS MAJESTY THE KING, Respondent.   ... The provisions of the said section 27 as enacted in 1924 and applicable to the 1923 taxation period insofar as they deal with rents and royalties are as follows; “ 27 …………. ... “Gabrielle St-Hilaire” St-Hilaire J.   CITATION: 2023 TCC 37 COURT FILE NO.: 2021-1804(IT)I STYLE OF CAUSE: 3792391 CANADA INC. ...

The Minister confirmed assessment of the gross negligence penalty by notice dated January 4, 2005. 9.          ... C.         STATUTORY PROVISIONS, GROUNDS RELIED ON AND RELIEF SOUGHT 11.        ... Stephan                    Firm:                                Felesky Flynn LLP        For the Respondent:                     John H. ...

Wilhelm Michael Taylor   JUDGMENT           The appeals from assessments made under Part IX of the Excise Tax Act, for the period from April 2, 2003 to June 30, 2005 and the period of March, 2007 are allowed, in part, and the assessments are referred back to the Minister of National Revenue for reconsideration and reassessment based on the following: 1.       ... The monthly Goods and Services Tax (“GST”) reporting periods that are in issue are those periods from April 2, 2003 to June 30, 2005 (the “First Period”) and the period of March, 2007 (the “Second Period”) (collectively the “Periods”). [4]              There are several issues which arose in these appeals. ... (Appellant’s Brief, paragraph 61). [13]         In 2005, and upon the advice of a tax consultant, BCF switched its ITC allocation method to the input method. ...