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Signed at Ottawa, Canada this 27th day of April 2007.   “J.E. Hershfield” Hershfield J.       ... Hershfield   DATE OF JUDGMENT: April 27, 2007   APPEARANCES:   Agents for the Appellant: Patrick Chaye and Orah Chaye   Counsel for the Respondent:     For the Intervener: Sara Fairbridge Oren Bick (Student-At-Law)   The Intervener himself     COUNSEL OF RECORD:   For the Appellant:   Name:     Firm:     For the Respondent: John H. ... Canada, 2005 TCC 173; Royal Winnipeg Ballet v. M.N.R, 2006 FCA 87; Art City in St. ...

THE LAW (a) The Statute [27] The relevant excerpted provisions of the Income Tax Act, RSC 1985, c.1, as amended (the “ Act ”) provide as follows: 1) PART I – INCOME TAX 2) DIVISION B – COMPUTATION OF INCOME Section 91(1) Amounts to be included in respect of share of foreign affiliate 91 (1) In computing the income […] of a taxpayer resident in Canada, there shall be included, in respect of each share owned by the taxpayer of a controlled foreign affiliate as income […] the foreign accrual property income of any controlled foreign affiliate […]. ... HAM: […] let's look at 95(2)(b)(i)(A)(I) […] when we break it down it starts off with the provision of services […] […] So, we have two conditions there, services, services by a foreign affiliate. ... That's the first deeming part, Your Honour. […] […] So, I'm going to just kind of skip everything between that comma and the next comma. […] MS. ...

Likelihood of Success [3]   Mr. Sweetman claimed donation tax credits in his 2004, 2005, 2006 and 2007 tax years in relation to almost $3,000,000 in gifts he claims to have made through a promoted program known as the Global Learning Gifting Initiative (“GLGI”). ... Drouin Deputy Attorney General of Canada Ottawa, Canada   [1]   2015 TCC 244. [2]   Mariano at para. 146. [3]   Written decisions were issued in Tudora v. ... The Queen, 2019 TCC 260. [4]   2017 FCA 19. [5]   Mariano v. The Queen, 2016 TCC 161. ...

Pierre, Articling Student   JUDGMENT   In accordance with the attached reasons for judgment:     The appeal from a reassessment made under the Income Tax Act in respect of the Appellant’s 2013 taxation year is dismissed. ... In 2005, he registered in a PhD program at Cairo University and completed some of the course work towards that PhD before Egypt selected him to come to Canada. ... [16]   Dr. Ismail registered for the PhD program at Cairo University in 2005 and testified he remained registered as a PhD student in Egypt throughout 2013. ...

“Gabrielle St-Hilaire” St-Hilaire J.   Citation: 2024 TCC 30 Date: 20240328 Docket: 2021-2037(IT)G BETWEEN: LARK INVESTMENTS INC., Appellant, and HIS MAJESTY THE KING, Respondent.   ... “Gabrielle St-Hilaire” St-Hilaire J.   SCHEDULE A   Further Amended Reply – Paragraph 67   67. ... Bureau 2500, 1, Place Ville Marie Montréal (Québec) H3B 1R1   For the Respondent: Shalene Curtis-Micallef Deputy Attorney General of Canada Ottawa, Canada   ...

(m)- for any device or equipment for use by the patient that             (i)     is of a prescribed kind,             (ii)    is prescribed by a medical practitioner,             (iii) is not described in any other paragraph of this subsection, and             (iv) meets such conditions as may be prescribed as to its use or the reason for its acquisition, to the extent that the amount so paid does not exceed the amount, if any, prescribed in respect of the device or equipment; Section 5700 of the Income Tax Regulations reads in part 5700.    ... (b)      Were they devices designed to assist an individual in walking? ... The Queen, [1994] 4 C.T.C. 2005 in which Rowe, J. of this Court dismissed the appeal of a wife who attempted to deduct as a medical expense the cost of purchasing and installing a hot tub which was prescribed by her husband's arthritis specialist. ...

Scott Bodie” Bodie J.   Citation: 2025 TCC 70 Date: 20250506 Docket: 2021-1465(GST)G BETWEEN: MEDSLEEP INC., Appellant, and HIS MAJESTY THE KING, Respondent.   ... The transfer is a capital transaction at the outset — at the time the agreement is entered into. ... Mr Tsambourlianos, under these agreements, all four types, are — in-in MedSleep’s opinion is — are Sleep Physicians paying for something supplied by — A. ...

I think any doubt arising from the difficulties of the language should be resolved in favour of the claimant. … [11]         Similarly, Iacobucci J. in Rizzo & Rizzo Shoes Ltd. ... It seems to me that, by limiting its analysis to the plain meaning of ss. 40 and 40a of the ESA, the Court of Appeal adopted an overly restrictive approach that is inconsistent with the scheme of the Act. [12]         The aforementioned statements have been referenced by this Court in several decisions relating to the determination of insurable hours under this Act (MacKenzie, at paragraphs 43 to 44; Sutton v MNR, 2005 TCC 125, [2005] TCJ No. 257, at paragraph 17; Kuffner v MNR, [2001] TCJ No. 23, at paragraph 15; and Bylow v MNR, [2000] TCJ No. 187, at paragraph 8). ... Pentney Deputy Attorney General of Canada Ottawa, Canada     ...

There were three components of the medical expenses:                                 Whirlpool Spa                                       $8,761.49                                 Travel Costs                                                          4,677.75                                 Miscellaneous                                       1,657.82                                 Total                                                        $15,097.06 By notice of reassessment dated November 1, 1999, the Minister of National Revenue allowed only the following amounts as medical expenses:                                 Travel Costs                                                          $5,147                                 Miscellaneous                                       1,657                                 Total                                                                        $6,804 The Appellant has appealed from that reassessment claiming that the cost of her whirlpool spa ($8,761) is a medical expense or, alternatively, that the cost of installing the whirlpool spa is a medical expense. ... (l.2)          for reasonable expenses relating to renovations or alterations to a dwelling of the patient who lacks normal physical development or has a severe and prolonged mobility impairment, to enable the patient to gain access to, or to be mobile or functional within, the dwelling; (m)           for any device or equipment for use by the patient that (i)             is of a prescribed kind, (ii)            is prescribed by a medical practitioner, (iii)           is not described in any other paragraph of this subsection, and (iv)           meets such conditions as may be prescribed as to its use or the reason for its acquisition; Having regard to any device or equipment "of a prescribed kind" within the meaning of paragraph (m), section 5700 of the Income Tax Regulations contains a list of what is described in the following words: 5700         For the purposes of paragraph 118.2(2)(m) of the Act, a device or equipment is prescribed if it is a                 (a)           ... ... Vantyghem's appeal was allowed. [10]          In Clark v. The Queen, [1994] 4 C.T.C. 2005, Judge Rowe dismissed the appeal of a wife who attempted to deduct as a medical expense the cost of purchasing and installing a hot tub which was prescribed by her husband's arthritis specialist. ...

He also bought, repaired and rented out real estate rental properties. [4]              The Appellant filed his Goods and Services Tax (“GST”) return for the 2003 Reporting Period on April 4, 2005. ... Miller J.   CITATION: 2016TCC47 COURT FILE NO.: 2015-3412(GST)I STYLE OF CAUSE: TODD LAMOUREUX AND HER MAJESTY THE QUEEN PLACE OF HEARING: Edmonton, Alberta DATE OF HEARING: February 15, 2016 REASONS FOR JUDGMENT BY: The Honourable Justice Valerie Miller DATE OF JUDGMENT: February 22, 2016   APPEARANCES:   For the Appellant: The Appellant himself Counsel for the Respondent: Gergely Hegedus   COUNSEL OF RECORD: For the Appellant: Name:     Firm:   For the Respondent: William F. Pentney Deputy Attorney General of Canada Ottawa, Canada     ...