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Miller J.           Citation: 2012TCC16 Date: 20120110 Docket: 2011-1456(IT)I BETWEEN: MAVIS TIDD, Appellant, and   HER MAJESTY THE QUEEN, Respondent.   ... By 2004 or 2005, she was recognized by the congregation as a minister in the church. [12]          The Appellant oversaw various ministries and when he was Senior Pastor with TICC, Mr. ... Miller J.   CITATION:                                       2012TCC16   COURT FILE NO.:                            2011-1456(IT)I   STYLE OF CAUSE:                          MAVIS TIDD AND                                                           HER MAJESTY THE QUEEN   PLACE OF HEARING:                     Toronto, Ontario   DATE OF HEARING:                       December 5 & 8, 2011   REASONS FOR JUDGMENT BY:    The Honourable Justice Valerie Miller   DATE OF JUDGMENT:                    January 10, 2012   APPEARANCES:   Counsel for the Appellant: Richard Yasny Counsel for the Respondent: Alisa Apostle   COUNSEL OF RECORD:          For the Appellant:                             Name:                      Richard Yasny                             Firm:                     Payne Law Professional Corporation          For the Respondent:                    Myles J. ...

Introduction [1]   This is an appeal by Doctor Mary Ruby Ellaway (the “ Appellant ”) against the reassessment of her 2016 taxation year (the “ Taxation Year ”) by notice of reassessment dated September 12, 2017 (the “ Reassessment ”). ... Facts [2]   At the commencement of the hearing the parties tendered a Statement of Agreed Facts (the “ SAF ”), which states as follows: 1.   ... The assumptions of fact that are not explicitly addressed in the SAF are as follows: a)   The Appellant is an Australian citizen. b)   The Appellant had a work permit in 2003 to 2005 allowing her to work in Canada. c)   Before February 3 rd, 2016, the Appellant kept no residential ties with Canada.... [4]   These assumptions of fact are to be accepted by the Court as true unless the Appellant demolishes the assumptions. [1] [5]   The Appellant testified that she left Australia on February 2, 2016 and arrived in Canada on February 3, 2016 to take up employment as a doctor. ...

The Queen, 2014 DTC 1151 [at at 3487], 2014 TCC 183 (Informal Procedure)         Docket: 2013-421(IT)I BETWEEN: Carrie Pekofsky, Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... “Lucie Lamarre” Lamarre J.       Citation: 2014 TCC 183 Date: 20140603 Docket: 2013-421(IT)I BETWEEN: Carrie Pekofsky, Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... Pentney Deputy Attorney General of Canada Ottawa, Canada     [1]           In court, the appellant said that she also claimed the credit for the 2009 taxation year. ...

The Appellant argues only that the tax rate was not set by Parliament but is determined by the Minister alone resulting in a delegation of tax authority to the Minister. [22]   Frankly, I do not agree with the Appellant or any of its reasons in support of its position. [23]   Firstly, the Appellant argues that the principle of statutory interpretation that must be applied is that of the textual, contextual and purposive approach enunciated by the Supreme Court of Canada in Canada Trustco Mortgage Co. v Canada, [2005] 2 S.C.R. 601, 2005 SCC 54 (“ Canada Trustco ”) at paragraphs 10 and 11: 10   … 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.   ... C.   Conclusion [95]     For the above reasons, I find that the answer to both questions within this Motion is No. ... Drouin Deputy Attorney General of Canada Ottawa, Canada     ...

On January 27, 2005 they transferred it to R.E.L. (Exhibits A-11 and A-10). ... Kwan Counsel for the Respondent: Marla Teeling COUNSEL OF RECORD:        For the Appellant:                    Name:                              Denny W.F. Kwan                    Firm:                                Fraser Milner Casgrain LLP        For the Respondent:                     John H. ...

A review of Exhibit A‑2 shows that there is reference to ‟ Cook ˮ or ‟ French Cook. ... M.R.N., 2005 FCA 334, para. 11), namely: i.        The performance of work; ii.       ... Canada (Minister of National Revenue), 2005 FCA 334.... [43]        In short, in my opinion there is no antinomy between the principles of Quebec civil law and the so-called common law criteria used to characterize the legal nature of a work relationship between two parties. ...

Miller J.           Citation: 2014TCC84 Date: 20140318 Docket: 2013-1231(IT)I BETWEEN: NEIL JOHNSON, Appellant, and   HER MAJESTY THE QUEEN, Respondent.   ... Lovie’s investigation related to the 2002 to 2005 years, inclusive. [10]         Pursuant to search warrants issued during the investigation, Ms. ... The Minister was justified in reassessing the Appellant beyond the limitation period. [35]         The appeal is dismissed.            ...

The Court went on, at paragraph 33, to state that [33]      … in a case where consideration has to be paid, the recipient is the one who, ultimately, under an agreement for a supply [according to paragraph (a)] or otherwise [according to paragraph (b)], is liable to pay that consideration. [60]         I made similar observations in the decision in Bondfield Construction Co. (1983) Ltd. v The Queen, 2005 TCC   78, [2005] TCJ No. 239: [121]    Under subsection 169(1), the person entitled to claim the ITC is the person to whom the supply is made; and under subsection 123(1) that person is deemed to be the “recipient”. ... Although this tax was collected in error, the Respondent argued that the Appellant is still obligated to remit it even though it has been collected in error (800537 Ontario Inc. v Canada, 2005 FCA 333, [2005] FCJ No. 1732). ... Yaskowich   Firm: Felesky Flynn LLP For the Respondent: William F. Pentney Deputy Attorney General of Canada Ottawa, Canada     ...

Both parties’ counsel’s arguments at the hearing were supplemented with later written submissions. [2]              The trust was established by deed of trust creating the Fiducie Famille Mathio Pellerin in January 2005 (the “trust”) for the benefit of, among others, Mathio Pellerin, his children and his grandchildren, from their birth or their adoption, as well as any legal person controlled by Mathio Pellerin. ... The FIDUCIE FAMILLE MATHIO PELLERIN (the Trust) set up on January 15, 2005 (Al-1) is a “personal trust” [3] as defined in the Income Tax Act, R.S.C. 1985, c. 1 (5th Suppl.) ... The “ the aggregate of all amounts ” in issue within the meaning of section 2.1 of the Tax Court of Canada Act is •          $12,211 for the 2008 taxation year; •          $1,838 for the 2009 taxation year; and •          $991 for the 2010 taxation year. ...

There was no evidence of the amount of professional fees for 2002 however the Appellant produced a receipt dated August 9, 2005 indicating that the fees were $214 (including GST) in that year. This would mean that fees increased from $160.50 in 2001 to $214 in 2005 or approximately, on average, $13.37 / year. ... Webb DATE OF JUDGMENT:                     April 18, 2007 APPEARANCES: For the Appellant: The Appellant himself Counsel for the Respondent: Andrew Miller COUNSEL OF RECORD:        For the Appellant:                    Name:                                                 Firm:        For the Respondent:                     John H. ...