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He quoted the following passage from Bulk Transfer Systems Inc v The Queen, 2005 FCA 94 at paragraph 33: The balance in the RDTOH account at the end of a particular year is reduced in the following year by the amount of dividend refunds to which the corporation has become entitled as a result of the payment of taxable dividends to its shareholders. [17]         Counsel further argued that there are two conditions to the entitlement of a dividend refund in subsection 129(1). ... According to his conclusion, if a corporation failed to file its tax return within three years after its year end, it was not entitled to receive a “ refund of an amount” and therefore its “dividend refund” was nil. [24]         It is widely recognized that statutory provisions must be interpreted with regard to their text, context and purpose harmoniously with the scheme and object of the Act as a whole: Canada Trustco Mortgage Co v The Queen, 2005 SCC 54 at paragraph 10. ... The Minister subtracted the respective amount in computing the appellant’s refundable dividend tax on hand (colloquially referred to as RDTOH) at the end of taxation year for 2007, 2008, 2009, 2010 and 2011 (as further detailed in Schedule “A” attached):   Taxation Year for Computation of RDTOH at end of Taxation Year – s.129(3) Amount of the Corporation’s Dividend Refund for its Preceding Taxation Year – s. 129(3)(d) Preceding Taxation Year   2007   $0   2006   2008   $24,600   2007   2009   $789   2008   2010   $0   2009   2011   $1,545   2010     Further to paragraph 16 above, additional details respecting the appellant’s computation of the “dividend refund” for the year claimed by the appellant in respect of the 2010 and 2011 taxation years is set out in Schedule “B” attached.   ...

Facts [7]              Mr. Langard incorporated Bearsden on December 29, 2005. ... Curiously, the Trust Agreement is made effective for one-half of the account on December 15, 2005 and for the remainder of the account on December 31, 2005. ... Langard’s “commodity participation” and for the following amounts on the following dates in 2007 for “commodities:”   April 30 $86,981.47   May 31 $26,670.89   June 30 $52,500.50   July 31 ($30,153.51)* * gain on commodities August 31 $15,551,51     [16]         Mr. ...

However no donations were claimed by the appellant in his 2004, 2005 and 2006 tax returns. ... The first question is whether he made the donations; if he did not, as I have concluded, there is a benefit.    ... For the reasons set out above I do not accept the appellant’s evidence.    ...

Thompson and was aware that he was claiming refunds for the 2005, 2006 and 2007 taxation years. [35] The Appellant signed the request on or around June 15, 2009 and filed it by mail. [36] After Mr.  ... The claim for the loss not only eliminated his income for 2008 but created a non-capital loss of $522,826 that the Appellant attempted to carryback to his 2005, 2006 and 2007 taxation years. ... However, it seems unlikely, given the Appellant’s 2008 income and the nature of his employment, that the Appellant’s income was significantly different in 2005, 2006 and 2007. [62] The suggestion that the Appellant relied on Mr.  ...

Bocock Appearances:   Counsel for the Appellant: Louise Summerhill     Counsel for the Respondent: Meghan Cowan Charles Camirand   JUDGMENT             IN ACCORDANCE with the Reasons for Judgment attached THIS COURT ORDERS THAT:   1.        ... Li, Principles of Canadian Income Tax Law (5th ed. 2005), at p. 569; Shell Canada Ltd. v. ... Ontario, is, in turn, a “prescribed” property or service within the definition of “specified property or service” pursuant to paragraph 28(1)(e) of the Regulations and subsection 236.01(1) of the ETA. [9]               2005 SCC 54, [2005] 2 S.C.R. 601. [10]             2006 SCC 20. [11] Ibid at paragraph 24. [12] 80 DLR(3d) 289. [13] SC 1970-71-72, c-7. [14] [1993] 2 FC 179 (FCA). [15] 2016 TCC 12. [16] Ibid, at paragraph 22. [17] [1996] GSTC 90, [1996] FCJ No 1621 (FCA). [18] Ibid at para 3. [19] Regulations, s. 31(1). [20] “Financial institution” is defined in sections 123 and 149(1) of the ETA. [21] Placer Dome, at paragraphs 45 and 46 [22] Placer Dome, at paragraphs 45-46. [23] Regulations, s. 26, “production”. [24] Placer Dome, at paragraph 46. ...

C.        The Purchase and Sale of the Equipment            7.         ... The terms of the Lease include the following:            (a)          the term of the Lease is for an initial period ending December 1, 2014;            (b)          the Rent Payments under the Lease are based upon an effective rate of 8.5%;            (c)          MAIL, as lessee, is required to make semi-annual payments to the Appellant as lessor in the amounts set out in "Schedule C" attached to the Lease (the "Rent Payments"); and            (d)          MAIL is provided with an option to purchase the Equipment (the "Option Price") CDN $84 million being the First Option Value on December 1, 2005 and another option exercisable at the fair market value on December 1, 2014. ... On or about December 17, 1996 MAIL applied the Pre-payment funds as follows:            (a)          MAIL placed on deposit with the RBC an amount equal to the Loan (approximately $97.35 million (CDN) (the "Defeasance Payment"); and            (b)          MAIL paid the balance of the Pre-payment (approximately $19 million) to Royal Bank of Canada Trust Company (Jersey) as trustee of the Maple Assets Charitable Trust ("RBC Jersey") on the condition that RBC Jersey use these funds to purchase a Government of Ontario bond (the "Bond"), maturing on the December 1, 2005. 24.       ...

I-   INTRODUCTION [1]   Indusol Industrial Control Ltd. (“ Indusol ” or the “ Appellant ”) filed an appeal with this Court in respect of a reassessment, the notice of which is dated July 21, 2014, made under the Income Tax Act (R.S.C. 1985, c. 1 (5th Supp.)) (the “ Act ”) for its 2012 taxation year, being the period from April 1, 2011 to March 31, 2012 (the “ 2012 taxation year ”). [2]   In so reassessing, the Minister of National Revenue (the “ Minister ”) was of the view that the activities undertaken by Indusol with respect to a project called the “ Draught [Draft] Information System ” (the “ DIS ” or the “ DIS Project ”) during the 2012 taxation year did not meet the criteria of the definition of scientific research and experimental development (“ SR&ED ”) in subsection 248(1) of the Act. ... Canada, 2005 SCC 54, at paragraph 10, [2005] 2 S.C.R. 601). The Supreme Court also indicates that when the words are precise and unequivocal, their ordinary meaning will play a dominant role, but if the words can support more than one reasonable meaning, the ordinary meaning of the words will play a lesser role. [148]   As indicated above, SR&ED tax incentive provisions should be given a fair, large and liberal construction and interpretation. ...

., 2007 TCC 212       Docket: 2006-1252(EI) BETWEEN: BERTRAND CÔTÉ, Appellant, and   THE MINISTER OF NATIONAL REVENUE, Respondent. ... Montreal: APFF, 2005), Justice Pierre Archambault of this Court describes, with regard to any period of employment after May 30, 2001, the method to be used by the courts since the coming into force, on June 1, 2001, of section 8.1 of the Interpretation Act, S.R.C. (1985), c. 1-21, amended, when dealing with a dispute like this one. ... Savoie   DATE OF JUDGMENT:                    May 4, 2007   APPEARANCES:   For the Appellant: The Appellant himself     Counsel for the Respondent: Mounes Ayadi   COUNSEL OF RECORD:          For the Appellant:                        Name:                                                    Firm:          For the Respondent:                    John H. ...

Canada, 2005 SCC 54, [2005] 2 S.C.R. 601, at par. 10 (" Trustco Mortgage "): "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. ... " [53] In addition, the appellant submits that the preposition " pour " [for] (before the word " année " [year]) means " le moment où quelque chose doit se faire " [the time when something should happen] and is synonymous with " pendant " [during], " au cours de " [in the course of], " à l'égard de " [with respect to] and " quant à " [regarding]. [54] This Court agrees that the preposition " pour " means " à l'égard de " and " quant à " but it does not mean " pendant " or " au cours de. ... In fact, section 2 uses the words "in the year" (in French, " au cours de l'année ") and "for the year" (in French, " pour l'année "). ...

Signed at Toronto, Ontario this 5 th day of October 2011.   “J. M. Woods” Woods J.         ... DOSHI, Appellant,   and   HER MAJESTY THE QUEEN, Respondent.     REASONS FOR ORDER     Woods J ... Leslie Morancie-Alexis at CRA’s International Tax Office in Toronto advised me on February 7, 2005 that the CRA had undertaken a review of the “Deemed Disposition” clause.  ...