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She was also thinking about returning to school which she did several months later in January 2005. ... (i)          employment if the employer and employee are not dealing with each other at arm's length.... 5(3)    For the purposes of paragraph (2)(i),...           ... M.N.R., [2005] T.C.J. No. 266, adequately review the history and current state of the law in respect to appeals arising pursuant to paragraph 5(3)(b). ...

Marin, 2005 CanLII 50228 (QC CQ) (“ Marin ”), in which the respondent challenged an assessment on the grounds that she had resigned as a director of the debtor company. ... The Queen, 2009 TCC 175 (“ Sandhu ”), in which Justice Jorré found that there was no evidence that the appellant had agreed to be a director and that there was an error in the initial declaration. ... For the Respondent: François Daigle Deputy Attorney General of Canada Ottawa, Canada   ...

The Queen, 2018 TCC 170       Dockets: 2013-1066(IT)G 2013-1327(IT)G BETWEEN: DEVON CANADA CORPORATION, Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... Drouin Deputy Attorney General of Canada Ottawa, Canada   [1]   Income Tax Act, RSC 1985, c.1 (5 th supplement), as amended. [2]   Exhibit AR-1. [3]   Exhibit AR-2. ... Bodrug Estate v The Queen, [1990] 2 CTC 324 at 332, 90 DTC 6521 at 6526, ¶11 (FCTD); aff’d, [1991] 2 CTC 347, 91 DTC 5621 (FCAD). [64]   The Queen v Canada Trustco Mortgage Company, 2005 SCC 54, ¶74. [65]   Ibid., ¶74. ...

INTRODUCTION [1]    This is an Application to extend the time to file a Notice of Objection. ... Serota   Firm: BRS Tax Lawyers LLP Blank For the Respondent: Nathalie G. ... HMTQ, 2005 FCA 421, (leave to appeal to the SCC dismissed [2006] G.S.T.C. 44). [8] I note that, even if sent on the date of the Notice of Objection the Notice of Assessment would be timely in any event. [9] While there is no evidence to this effect, theoretically counsel could have obtained it acting as the Applicant’s agent. ...

Translation certified true on this 20 th day of January 2005. Colette Dupuis-Beaulne, Translator Citation: 2004TCC578 Date: 20040924 Docket: 2001-1102(IT)G BETWEEN: GIUSEPPE COLUBRIALE, Appellant, and HER MAJESTY THE QUEEN, Respondent. ... Fibers, the lease was $15,000 per month. [4]      The first building was destroyed by fire in 1989. ... Fibers had never been mentioned. [6]      The transfer of the title of ownership from the appellant to J.C. ...

Citation: 2006TCC220 Date: 20060411 Docket: 2005-3832(IT)I     BETWEEN: CAREY OGILVIE, Appellant, and HER MAJESTY THE QUEEN, Respondent. ... Indeed his evidence leads me to believe that he set the support at that amount. [3]      The assessments rely on the amending document being signed when dated and on it making changes to the support amount payable so as to create a "commencement day" as defined in subsection 56.1(4) of the Income Tax Act (the " Act "). [4]      The existence of a commencement day would bring the child support payments under the post April 1998 tax rules under which such payments are no longer deductible to the Appellant. [5]      The Respondent did not call the former spouse to give evidence. ... While this testimony might seem somewhat suspect, the Appellant produced a May 2005 sworn statement from the FRO stating that the 1995 Order had never been varied by order or agreement. ...

JOHAL, Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent.   ... PLACE OF HEARING: Vancouver, British Columbia DATE OF HEARING: November 18, 2016 REASONS FOR JUDGMENT BY: The Honourable Justice Valerie Miller DATE OF JUDGMENT: December 6, 2016   APPEARANCES:   For the Appellant: The Appellant herself Counsel for the Respondent: Chantelle Coulson   COUNSEL OF RECORD: For the Appellant: Name:     Firm:   For the Respondent: William F. Pentney Deputy Attorney General of Canada Ottawa, Canada     ...

Elander, a lawyer, was a tax debtor owing more than $500,000.00 in taxes, penalties and interest assessed or reassessed in respect of the 1999, 2000 to 2005 inclusive and 2007 taxation years at the time he deposited funds in either the Appellant’s joint and several bank account with him or the Appellant’s own bank accounts. ... Pizzitelli DATE OF JUDGMENT: September 28, 2017   APPEARANCES:   For the Appellant: The Appellant herself Counsel for the Respondent: Whitney Dunn   COUNSEL OF RECORD: For the Appellant: Name: n/a   Firm:   For the Respondent: Nathalie G. Drouin Deputy Attorney General of Canada Ottawa, Canada     ...

Leon in 2005 for some reason. [12] Provincial corporate registries are not determinative on the issue of whether a person is or is not a director for purposes of the director liability provisions of the Act. ... Ferri’s evidence that this was in 2005. There is no evidence that Mr. ... “Patrick Boyle” Boyle J.   CITATION: 2024 TCC 25 COURT FILE NO.: 2017-2569(IT)G STYLE OF CAUSE: ANDREW FERRI AND HIS MAJESTY THE KING PLACE OF HEARING: Toronto, Ontario DATE OF HEARING: March 14, 15 and 16, 2023 REASONS FOR JUDGMENT BY: The Honourable Justice Patrick Boyle DATE OF JUDGMENT: February 28, 2024   APPEARANCES:   Counsel for the Appellant: Jeff Warwick Counsel for the Respondent: Khalid Tariq   COUNSEL OF RECORD: For the Appellant: Name: Jeff Warwick   Firm:   For the Respondent: Shalene Curtis-Micallef Deputy Attorney General of Canada Ottawa, Canada     ...

" Réal Favreau " Favreau J. Translation certified true on this 8th day of April 2021. ... Drouin Deputy Attorney General of Canada Ottawa, Canada     ...