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TCC
1663255 Ontario Inc. v. M.N.R., 2011 TCC 19
., 2011 TCC 19 Citation: 2011 TCC 19 Date: January 24, 2011 Dockets: 2010-659(CPP) 2010-660(CPP BETWEEN: 1663254 ONTARIO INC., Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent. ... Skelton and this witness collaborating on a business arrangement in March of 2005. ... AND MINISTER OF NATIONAL REVENUE PLACE OF HEARING: Ottawa, Canada DATE OF HEARING: December 2, 2010 REASONS FOR JUDGMENT BY: The Honourable Justice Diane Campbell DATE OF ORAL JUDGMENT: December 3, 2010 APPEARANCES: Agent for the Appellant: Susan Tataryn Counsel for the Respondent: Serena Sial Andrew Miller COUNSEL OF RECORD: For the Appellant: Name: Firm: For the Respondent: Myles J. ...
TCC
Kossow v. The Queen, 2010 TCC 279
Miller J. Citation: 2010TCC279 Date: 20100521 Docket: 2005-1974(IT)G BETWEEN: KATHRYN KOSSOW, Appellant, and HER MAJESTY THE QUEEN, Respondent. ... Kossow filed her Appeal with the Tax Court of Canada in June 2005. There are well over a thousand taxpayers who made donations to the Ideas Canada Foundation in similar circumstances to Ms. ... [4] 1983 CarswellNat 362. [5] 2010 TCC 109. [6] 2007 TCC 703. ...
TCC
Prevost Car Inc. v. The Queen, 2008 TCC 231
Rip" Rip A.C.J. Citation: 2008TCC231 Date: 20080422 Dockets: 2004-2006(IT)G 2004-4226(IT)G BETWEEN: PRÉVOST CAR INC., Appellant, and HER MAJESTY THE QUEEN, Respondent. ... [86] As a result of abuse of the treaty by conduit companies, Indonesia terminated its tax treaty with Mauritius effective January 1, 2005, thus increasing to 20 percent the withholding on the interest payments between the Parent and the Issuer. ... I also note that the Court of Appeal had regard to substance over form, as required by the law of Indonesia (paras. 18 and 24). [34] [2005] EWHC 2103 (Ch). [35] Ibid., para. 46. [36] Ibid., para. 49. [37] Supra, note 20, para. 42. [38] Para. 43. [39] In his report Professor van Weeghel quotes from comments by the Dutch Underminister of Finance in a Ministry of Finance memorandum to the Finance Committee of the Dutch Parliament in the 1987-1988 Parliamentary year. [40] The Civil Code of Quebec recognizes a trust: articles 1260 to 1298. [41] For example, s.s. 82(3), subpara. 82(1)(a)(1.1). ...
TCC
Gilbert v. The Queen, 2011 TCC 155
Translation certified true on this 9th day of May 2011 François Brunet, Revisor Citation: 2011 TCC 155 Date: 20110310 Docket: 2008-3145(IT)G BETWEEN: JEAN-PIERRE GILBERT, Appellant, and HER MAJESTY THE QUEEN, Respondent. ... (j) Under a deed of release dated November 10, 2005, the Garantie des Bâtiments Résidentiels Neufs de l’APCHQ Inc. struck from the registration of hypothecary rights, the notice of legal hypothec resulting from a judgment dated July 13, 2005, concerning the Beaubien building. ... [23] For these reasons, the appeal is dismissed, with costs. ...
TCC
McGillivray Restaurant Ltd. v. The Queen, 2015 DTC 1030 [at at 134], 2014 TCC 357, aff'd supra
“Patrick Boyle” Boyle J. Citation: 2014 TCC 357 Date: 20141128 Docket: 2012-2500(IT)G BETWEEN: McGILLIVRAY RESTAURANT LTD., Appellant, and HER MAJESTY THE QUEEN, Respondent. ... Howard that the McGillivray location be operated by another new corporation, the Appellant McGillivray Restaurant Ltd. [12] McGillivray Restaurant Ltd. was incorporated in 2005 by Mr. ... Thereafter the terms of the Franchise Agreement described above applied equally to, and in respect of, McGillivray Restaurant Ltd. [16] The Pembina Highway location closed on December 2 nd, 2005. ...
TCC
Le restaurant Le Relais de Saint-Jean Inc. v. The Queen, 2009 TCC 515
Signed at Montreal, Quebec, this 15 th day of October 2009. " Lucie Lamarre " Lamarre J. ... Canada, 2005 FCA 425, paragraph 20). This Court stated that the taxpayer “knows how and why it is run in a particular fashion rather than in some other ways. ...
TCC
Bensouilah v. The Queen, 2010 DTC 1018 [at at 2624], 2009 TCC 440 (Informal Procedure)
[OFFICIAL ENGLISH TRANSLATION] REASONS FOR JUDGMENT Angers J ... The appellant himself signed his 2004, 2005 and 2006 tax returns and they were all filed at the same time. ... [31] The appeals are dismissed. Signed at Ottawa, Canada, this 7th day of October 2009. ...
TCC
Labrecque c. La Reine, 2007 TCC 195 (Informal Procedure)
La Reine, 2007 TCC 195 (Informal Procedure) Docket: 2006-2149(IT)I BETWEEN: MANON LABRECQUE, Appellant, and HER MAJESTY THE QUEEN, Respondent. ... [13] In Bailey v. The Queen, 2005 DTC 673, Rip J. of this Court made the following comment about section 63 of the Act: Section 63 provides a limited tax deduction for parents who require their children to be supervised because they are employed outside the home. ... Sims, Q.C. Deputy Attorney General of Canada Ottawa, Canada ...
TCC
Gin Max Enterprises Inc. v. The Queen, 2007 TCC 223 (Informal Procedure)
McArthur Appearances: Counsel for the Appellant: Charles Leibovich and Kim Nelson Counsel for the Respondent: Michael Ezri____________________________________________________________________ JUDGMENT The appeal from the reassessment made under the Excise Tax Act, notice of which is dated May 8, 2005, and bears number 01EE0102577, is allowed and referred back to the Minister of National Revenue for reconsideration and reassessment only on the basis that the penalties are waived. Signed at Ottawa, Canada, this 4th day of May, 2007. "C.H. McArthur McArthur J. ... McArthur DATE OF JUDGMENT: May 4, 2007 APPEARANCES: Counsel for the Appellant: Charles Leibovich and Kim Nelson Counsel for the Respondent: Michael Ezri COUNSEL OF RECORD: For the Appellant: Name: Charles Leibovich and Kim Nelson Firm: Wasserman, Stotland, Bratt, Grossbaum For the Respondent: John H. ...
TCC
Tremblay v. M.N.R., 2009 TCC 30
Signed at Montréal, Quebec, this 21st day of January 2009. "Réal Favreau" Favreau J. ... [2] Subsection 5(2) of the Act provides, inter alia, as follows: 5. ... ... According to a Quebec government publication, the median hourly wage of a server on the North Shore was $10 between 2003 and 2005, while according to Service Canada (Wage Report, published October 24, 2008), the average wage of a server on the North Shore was $8.10 per hour ...