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Question 1 – What evidence was relied upon? [25]   This is a mixed question of fact and law. ... Bocock DATE OF JUDGMENT: September 19, 2018   APPEARANCES:   For the Appellant: The Appellant himself Counsel for the Respondent: Max Matas Jamie Hansen   COUNSEL OF RECORD: For the Appellant:   Name:     Firm:   For the Respondent: Nathalie G. Drouin Deputy Attorney General of Canada Ottawa, Canada     [1] R. v Colin McCartie et al., 2015 BCPC 0069 ; 2015BCPC 0233 ; and 2015 BCPC 0254. [2] Rule 58 changed in February 7, 2014: SOR/2014-26, s.6. [3] 2016 TCC 171, at paragraphs 10, 11 and 12. [4] Paletta, supra, at paragraph 12. [5] Ibid, at paragraph 25. [6] Ibid. [7] Paletta v HMQ, 2017 FCA 33. [8] 2078970 Ontario Inc. v HMQ, 2017 TCC 173 at paragraph 7. [9] Suncor Energy v HMQ, 2015 TCC 210 at paragraph 26. [10] Jurchison v Canada [2011] FCJ No. 126 at paragraph 11. [11] Warawa v Canada, 2005 FCA 34 at paragraph 6. [12] McIntyre v HMQ, 2014 TCC 111 at paragraph 36. [13] R. ...

Buckingham, 2011 FCA 142 (“ Buckingham ”) and Balthazard v. Canada, 2011 FCA 331 (“ Balthazard ”). In Balthazard, Mainville J.A. summarized the matter as follows (para. 32): 32.   (…) a.   ... Wise, 2005 SCC 68, (2004) 3 S.C.R. 461 (“ Peoples ”), was a corporate law case in which the Supreme Court of Canada dealt with a director’s duty of loyalty and duty of care under paragraphs 122(1)(a) and (b) of the Canada Business Corporations Act, R.S.C. 1985, c. ...

the Respondent’s motion to quash under paragraph 53(3)(c) of the Tax Court of Canada Rules (General Procedure) (the “ Rules ”) is dismissed; 2.      ... All property passing to the Trustee under the bankrupt estate is subject to the Trustee’s sole right, subject to section 38 of the BIA, to initiate an appeal and the bankrupt retains no residual rights: 4028490 Canada Inc. v Canada, [2005] TCJ No. 95(QL). ... Pentney Deputy Attorney General of Canada Ottawa, Canada     ...

Malik began looking into financing. [6]              Mr. Malik and his wife had made poor financial choices in 2005 that resulted in each of them declaring personal bankruptcy in 2006. ... Graham DATE OF JUDGMENT: April 15, 2015   APPEARANCES:   Agent for the Appellant: Stephen Ji Amy Sujae Lee Counsel for the Respondent: Adam Gotfried   COUNSEL OF RECORD: For the Appellant: Name:     Firm:   For the Respondent: William F. Pentney Deputy Attorney General of Canada Ottawa, Canada     [1]           I do not have evidence of the actual closing date. ...

The Appellant’s appeals of the reassessments of her 2005, 2006, 2007, 2010 and 2011 tax years are hereby quashed. ... The Queen (“ Mariano ”), Justice Pizzitelli dismissed their appeals. [1] [9] The Minister accordingly confirmed the reassessments of the taxpayers who had signed Agreements to be Bound. ... The Appellant’s appeals of the reassessments of her 2005, 2006, 2007, 2010 and 2011 tax years are quashed. ...

The shareholders at that time were the Appellant, George Sofos and Chris Kambouris. 3.          1174429 Ontario Inc. was at all material times a Canadian Controlled Private Corporation ("CCPC") as defined by the Income Tax Act. 4.          1174429 Ontario Inc. was engaged in active business from the date of its incorporation until sometime in the latter part of 2005 when it ceased to carry on business. 5.          ... (ii)       The factors a creditor should take into account are: [3]             "1.         ... McNevin                             Firm:                      Ducharme Fox, LLP        For the Respondent:                     John H. ...

CITATION:                                        2007TCC31 COURT FILE NO.:                             2006-2362(GST)I and 2006-2723(GST)I STYLE OF CAUSE:                           Leslie E. ... Miller DATE OF JUDGMENT:                     January 19, 2007 APPEARANCES: For the Appellants: The Appellants themselves Counsel for the Respondent: Tyler Lord COUNSEL OF RECORD:        For the Appellant:                           Name:                                                   Firm:        For the Respondent:                     John H. Sims, Q.C.                                                           Deputy Attorney General of Canada                                                           Ottawa, Canada [1]           2004 DTC 2049. [2]           2000 DTC 6593. [3]           2004 SCC 68. [4]           97 DTC 5407. ...

Translation certified true On this 23 rd day of June 2017     François Brunet, Reviser   Citation: 2016 TCC 101 Date: 20160502 Docket: 2010-3810(IT)G BETWEEN: ANNIE SAUVIGNON, Appellant, and HER MAJESTY THE QUEEN, Respondent. ... The Queen, 2005 DTC 377, that a loan did not constitute a transfer of property within the meaning of section 160 of the ITA. [20]         However, in my opinion, the appellant has failed to show, on a balance of probabilities, that Mr.  ... Pentney Deputy Attorney General of Canada Ottawa, Canada     ...

Paragraph 8 of the Reply, reads: 8.          In so assessing and confirming the Appellant, the Minister relied on the following assumptions of fact:             a)      The Appellant is a financial institution;             b)     The Appellant contracted with various collection agencies in order to collect payment by its debtors who were in default;             c)      The task of the collection agencies was to recover and deposit the amounts in a trust account, the beneficiary of which was the Appellant;             d)     Within the parameters established by the Appellant these collection agencies could accept a lesser amount of the debt as a final settlement;             e)      In exchange for these services, the collection agencies receive a percentage of the amounts thus recovered. ... Judgment in that appeal has been reserved. [7]      Mr. Ezri's arguments on this point are as follows: There are three reasons why these cases should be heard in the usual manner rather than under Rule 58: 1)       The issue raised by this motion was the subject of a full trial on November 30, 2005 involving one of the same appellants. ... The collection services rendered by the collection agencies constitute financial services because they are described in any of the following paragraphs of the definition of "financial service" found in subsection 123(1) of the ETA:          (a)      the...receipt or transfer of money, whether effected by the exchange of currency, by crediting or debiting accounts or otherwise [...];          (d)      the...variation, transfer of ownership or repayment of a financial instrument (i.e., the debt securities giving rise to the amounts owing) [...];          (f)       the payment or receipt of money as...interest, principal...or any similar payment or receipt of money in respect of a financial instrument (i.e., the debt securities giving rise to the amounts owing) [...];          (l)       the agreeing to provide, or the arranging for, a service referred to in any of (the above) paragraphs [...]. [11]     Counsel referred to certain decisions of this court in which applications under section 58 of the Rules were considered: Webster et al. v. ...

The respondent is entitled to costs.                     Signed at Ottawa, Canada, this 2 nd day of March, 2007. ... Factual background [7]      The driving force behind these transactions was a Calgary businessman by the name of Sig Gutsche. [8]      In the late 1980s, Mr. ... The Queen, 2005 D.T.C. 1280 (T.C.C.), at para. 22 to 35. The statutory purpose test [38]     The appellant submits that he incurred an expense of $50,000 in each of the relevant taxation years for the purpose of oil and gas exploration. [39]     The principal provision at issue is paragraph (a) of the definition of CEE in s. 66.1(6), which reads: "Canadian exploration expense" of a taxpayer means any expense incurred after May 6, 1974 that is (a)    any expense including a geological, geophysical or geochemical expense incurred by the taxpayer (other than an expense incurred in drilling or completing an oil or gas well or in building a temporary access road to, or preparing a site in respect of, any such well) for the purpose of determining the existence, location, extent or quality of an accumulation of petroleum or natural gas (other than a mineral resource) in Canada, [...] ...