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The Appellant provided additional information by letters dated June 8, 2005, January 17, 2006, August 30, 2011 and November 15, 2011. ... ]     [20]         The parallel provisions of the Income Tax Act (the “ ITA ”) are found in sections 165 and 169. ... Canada, 2005 FCA 159 the taxpayer was a specified person and raised in its Notice of Appeal in the Tax Court of Canada the issue of due diligence with respect to automatic penalties under the ETA upon being assessed for additional net tax. ...

Translation certified true on this 30 th day of March, 2005. Colette Dupuis-Beaulne, Translator Docket: 98-763(UI) BETWEEN: FRANCINE PROVOST, Appellant and THE MINISTER OF NATIONAL REVENUE, Respondent. ... They are: (a)         the existence of a common mind which directs the bargaining for both parties to the transaction,                      (b)         parties to a transaction acting in concert without separate interests, and             (c)         " de facto " control.                     ... Translation certified true on this 30 th day of March 2005. Colette Dupuis-Beaulne, Translator [1]           Tibério's counsel admitted the assumption of fact set out at paragraph 6(a) of the Reply to the Notice of Appeal, which states that Tiva was incorporated in 1988. [2]           According to the admission made by counsel for the Appellants. [3]           According to the testimony of Ms. ...

Canada, 2005 SCC 54 [see par 10] to determine, namely whether there was an abuse of a particular provision of the Act. ... Clarke   Firm: QED Tax Law Corporation For the Respondent: Nathalie G. Drouin Deputy Attorney General of Canada Ottawa, Canada     ...

The Appellant did not have unreported income; and 2.   The Appellant is not liable for penalties under subsection 163(2) of the Act.   ... Tong’s credibility. [73]   However, on closer examination of the evidence, it is clear this is not correct. [43] In each of 2003, 2005, 2006, 2007, and 2008, Mrs. ... Canada 2005 FCA 2007. ...

“Patrick Boyle” Boyle J.   Citation: 2015 TCC 215 Date: 20150831 Docket: 2013-1257(IT)G BETWEEN: DINO AGOSTINI, Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... Her testimony was quite clear: there was no such safe. [1] [16]         Mr. ... While he claims to have had up to $140,000 in cash saved in his safe, he claims to have used it to spend significantly more, including in 2002 a $95,000 down payment on their triplex, a $9,000 replacement roof for it, and his $52,000 F350 pickup truck which he claims to have purchased for cash in 2005 (though no written record relating to his truck was offered into evidence). ...

Drouin Deputy Attorney General of Canada Ottawa, Canada   [1]   R.S.C., 1985, c. 1 (5th Supp.). [2]   Shell Canada Ltd. v. ... Canada, 2005 SCC 54, at paragraphs 18, 21 and 36. [4]   Copthorne, supra note 3 at paragraph 42. [5]   Canada Trustco, s upra note 3 at paragraph 20. [6]   Copthorne, supra note 3 at paragraph 35. [7]   Copthorne, supra note 3 at paragraphs 69 and 70. [8]   John Burghardt and Sarah Chiu, "Loss is Just a Four-Letter Word: Policy, Practice and Proposals" CTF, 2013 Conference Report, 14:1-43 at 14:7. [9]   Canada v. ... Canada, 2005 SCC 55 at paragraph 49. [17]   W.J. Strain, D.A. Dodge, V. ...

., 2006 TCC 249       Docket: 2003-4599(EI) BETWEEN: GAÉTAN BÉLAND, Appellant, and   THE MINISTER OF NATIONAL REVENUE, Respondent. ...   [35]     In Louis-Paul Bélanger v. M.N.R., 2005 TCC 36, Archambault J. of this Court analyzed a set of decisions of both the Federal Court of Appeal and the Tax Court of Canada on the issue of non-arm's length dealing and the process that the Court must follow in an appeal from a decision of the Minister based on the statutory provisions quoted above ... Signed at Ottawa, Canada, this 1st day of June 2006.       "François Angers" Angers J.     ...

The Queen, 2016 DTC 1018 [at 2629], 2016 TCC 10     Dockets: 2013-897(IT)G 2013-899(IT)G 2013-900(IT)G 2013-3334(IT)G BETWEEN: JEFFREY N. ... Analysis [25]         In Canada Trustco Mortgage Co. v. The Queen, [2005] 2 S.C.R. 601, the Supreme Court of Canada set out the approach to be taken in interpreting tax legislation, as follows: 10 It has been long established as a matter of statutory interpretation that “the words of an Act are to be read in their entire context and in their grammatical and ordinary sense harmoniously with the scheme of the Act, the object of the Act, and the intention of Parliament”: see 65302 British Columbia Ltd. v. ... Pentney Deputy Attorney General of Canada Ottawa, Canada     ...

The King, 2025 TCC 22 Docket: 2021-481(IT)G BETWEEN: CURTIS SIM, Appellant, and HIS MAJESTY THE KING, Respondent; Docket: 2021-781(IT)G AND BETWEEN: SHAWN SIM, Appellant, and HIS MAJESTY THE KING, Respondent.     ... Between 2004 and 2005 Curtis and Shawn each deposited shares of Manchester Inc. into the applicable brokerage account. ... Scott Bodie” Bodie J.   CITATION: 2025 TCC 22 COURT FILE NOS.: 2021-481(IT)G 2021-781(IT)G STYLES OF CAUSE: Curtis Sim v. ...

Staltari then appealed to the Ontario Municipal Board in order to preclude the Land being designated environmentally sensitive wetlands. [28]         Copies of two appeals by Flewellyn to the OMB dated January 13, 2005 were entered into evidence by the Respondent. [16] In cross-examination, Mr.  ... This concern was raised after the applications had been filed. [19] [29]         At some point between 2005 and the time of the donation, [20] while the appeal to the OMB was ongoing, the Ministry of Natural Resources (the “MNR”) requested permission to come onto the Land to assess its environmental status. ... (Toronto: Thomson Carswell, 2005) at pages 80-81, the authors describe the judicial concept of income as follows:   The courts have approached the question of what is income on a case-by-case basis, rather than providing an exhaustive definition. ...