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., 2014 TCC 190       Docket: 2013-1977(CPP) BETWEEN: ONTARIO REAL ESTATE ASSOCIATION, Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent, and   STEPHEN PAUL ARMSTRONG, Intervenor.   ... C-8 (the “ CPP ”) and the Employment Insurance Act, S.C. 1996 c. 23 (the “ EI ”). ... OREA is registered under the Ontario Private Colleges Act of 2005, SO 2005, c 28, Sch L, as a private career college. ...

The Queen, 2016 TCC 199 Docket: 2014-4517(IT)G BETWEEN: PAUL KVAS, Appellant, and   HER MAJESTY THE QUEEN, Respondent,   Docket: 2014-4518(IT)G AND BETWEEN: PETER KVAS, Appellant, and   HER MAJESTY THE QUEEN, Respondent.   ... Bocock” Bocock J.   Citation: 2016 TCC 199 Date: 20160915 Docket: 2014-4517(IT)G BETWEEN: PAUL KVAS, Appellant, and HER MAJESTY THE QUEEN, Respondent,   Docket: 2014-4518(IT)G   AND BETWEEN: PETER KVAS, Appellant, and   HER MAJESTY THE QUEEN, Respondent.   ... B.16 (the “ OBCA ”). Business was slow at first, but, meeting their objective of incorporation, CIA was placed on pre-approved bidders’ lists. [5]              CIA won and executed a big contract during 2005. ...

Signed at Ottawa, Canada, this 5 th day of October 2011.     “F.J. Pizzitelli” Pizzitelli J.         ... Minister of National Revenue 2005 TCC 173, Hershfield J of the Tax Court in analysing the Control factor stated at par 11:   However, in times of increased specialization this test  may be seen as less reliable, so more emphasis seems to be placed on whether the service engaged is simply “results” oriented; i.e. ...

The Queen, 2021 TCC 41 Docket: 2015-2662(IT)G BETWEEN: THE ESTATE OF PASQUALE PALETTA, Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... Any Offer of Settlement Made in Writing – Rule 147(3)(d) [25] No offer of settlement in writing was made by either party. 5. ... This required the Appellant to adduce additional evidence addressing the purpose of the trading, etc.   6. ...

Facts and preliminary remarks [2]              The appellants are the daughters of Bertrand Joyal and are therefore related persons under paragraph 251(2)(a) of the ITA. [3]              Mr. ... He also stated that in 2006 his daughters incorporated a company, injecting into it the money that he had given them from the inheritance, and that this company then purchased the land from the Estate. [27]         Bertrand Joyal acknowledged that he never kept a statement of account recording what he believed he owed his daughters for the services they had rendered. [28]         Angie is a dental assistant and has worked in a clinic since 2005. ... Pentney Deputy Attorney General of Canada Ottawa, Canada   ...

Canada, 2005 SCC 54. However, as the Court stated in Placer Dome Canada Ltd. v. ... Information about the appellant   The appellant is a non‑resident corporation.   ... Drouin Deputy Attorney General of Canada Ottawa, Canada     ...

Canada, 2005 SCC 54 (“ Canada Trustco ”), Lipson, Copthorne Holdings Ltd. v. ... The first amendment, which was made in 2005, was deemed to come into force as of that date and applies to transactions entered into after September 12, 1988. ... Canada, 2005 FCA 252 (“ Hammill ”) at paragraph 31. [4] The rate dictated by an applicable tax treaty overrides the 25% rate in Part XIII of the ITA by virtue of subsection 10(6) of the Income Tax Application Rules. [5] I entered the Joint Book into evidence as exhibit AR-1, but for clarity, I will refer to the two volumes in exhibit AR‑1 as the Joint Book. [6] See Nichols v. ...

  [16]   Mr. Fleury returned to the premises in February 2014, drafted the wiretap orders and had surveillance cameras installed outside. ...   [24]   Ms. De Larochellière also analyzed the photographs filed in evidence. ... The Queen, 2005 TCC 330, para. 21). [54]   The guilty plea entered by the appellant before the Court of Québec and evidence filed constitute extrajudicial admissions (article 2852 CCQ), which were introduced in evidence with the filing of the transcript reproducing them. ...

The Queen, [1980] 2 FC 269 (“ Tahsis ”), MacMillan Bloedel and Bernier. [12] Steve Coughlan, Canadian Law Dictionary, 7 th ed. ... (Toronto: Irwin Law, 2016) (“Sullivan”) at page 43. [33] [1957] S.C.R. 167 (“ Consolidated Glass ”). [34] [1968] 2 Ex CR 44, [1968] CTC 65, 68 DTC 5045 (“ D.W.S. ... Minister of National Revenue, [1955] S.C.R. 745 (“ Eli Lilly ”), Tip Top Tailors Ltd. v. ...

The Queen, [1996] 2 C.T.C. 2005 in support of this proposition. The Appellant also urged the Court to deal with compassion and understanding in accordance with recent decisions such as Tanguay v. ... Miller DATE OF JUDGMENT:                                       August 27, 2001 APPEARANCES: Agent for the Appellant:                     Meluccia Di Marco Counsel for the Respondent:              R. Scott McDougall COUNSEL OF RECORD: For the Appellant:                 Name:                                Firm:                  For the Respondent:                             Morris Rosenberg                                                                                 Deputy Attorney General of Canada                                                                                                 Ottawa, Canada 2000-1349(IT)I BETWEEN: EVELYN ELLEN WILSON, Appellant, and HER MAJESTY THE QUEEN, Respondent. ...