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Costs are awarded to the Appellant.             Signed at Ottawa, Canada, this 21st day of May, 2009.     ... Rossiter” Rossiter A.C.J.         Citation: 2009TCC272 Date: 20090521 Docket: 2006-1099(GST)G BETWEEN:   CITY OF CALGARY, Appellant, and   HER MAJESTY THE QUEEN, Respondent.   ... Canada, 2005 TCC 809, [2006] T.C.J. No. 56 (T.C.C.) at para. 95. [39]          The question of whether, and in what circumstances, a person’s undertaking of an activity for which the person receives funding from a government body constitutes the making of a supply to that body for consideration was considered by the Federal Court of Appeal in Des Chênes (Commission scolaire) v. ...

" [16]          An investigation concerning Réjean Simard was begun on September 13, 1999, and he was dismissed six weeks later. ... He is on probation until November 2005. [17]          Réjean Simard said that that period was very difficult for him. ... I have no reason to believe it is much higher at the present time. [36]          The total amount of the reassessments seems very high, first, compared with the amount received in 1996, and second, in relation to the appellant's annual income. [37]          By letter dated March 18, 2002, counsel for the respondent sent me the particulars of the assessments, which read as follows: [TRANSLATION] Table- Particulars of Assessments 1990 Unjustified refund                                 $2,125.75                 Interest on this amount between                        $ 973.59                                                                 March 28, 1996, and July 14, 2000 Interest received                   $ 55.08    Interest on this amount between                        $ 25.24                                                                 March 28, 1996, and July 14, 2000 Penalty 163(2)                                        $1,062.87                 Interest on this amount between                        $1,407.01                                                                 April 30, 1991, and July 14, 2000 Total                                                        $3,243.70                                 Total interest                                         $2,405.84                                                                                 Grand total for 1990                                                            $5,649.54 1991 Unjustified refund                                 $2,166.74                 Interest on this amount between                        $ 992.40                                                                 March 28, 1996, and July 14, 2000 Interest received                   $ 56.14    Interest on this amount between                        $ 25.71                                                                 March 28, 1996, and July 14, 2000 Penalty 163(2)                                        $1,083.37                 Interest on this amount between                        $1,160.24                                                                 April 30, 1992, and July 14, 2000 Total                                                        $3,306.25                                 Total interest                                         $2,178.35                                                                                 Grand total for 1991                                                            $5,484.60 1992 Unjustified refund                                 $1,415.00                 Interest on this amount between                        $ 648.08                                                                 March 28, 1996, and July 14, 2000 Interest received                   $ 372.15 Interest on this amount between                        $ 170.45                                                                 March 28, 1996, and July 14, 2000 Penalty 163(2)                                        $ 707.50 Interest on this amount between                        $ 629.63                                                                 April 30, 1993, and July 14, 2000 Total                                                        $2,494.65                                 Total interest                                         $1,448.16                                                                                 Grand total for 1992                                                            $3,942.81 1993 Unjustified refund                                 $ 845.27 Interest on this amount between                        $ 387.15                                                                 March 28, 1996, and July 14, 2000 Interest received                   $ 148.82 Interest on this amount between                        $ 68.16                                                                 March 28, 1996, and July 14, 2000 Penalty 163(2)                                        $ 422.63 Interest on this amount between                        $ 318.36                                                                 April 30, 1994, and July 14, 2000 Total                                                        $1,416.72                                 Total interest                                         $ 773.67                                                                                 Grand total for 1993                                                            $2,190.39 1994 Unjustified refund                                 $ 780.53 Interest on this amount between                        $ 357.49                                                                 March 28, 1996, and July 14, 2000 Interest received                   $ 61.99    Interest on this amount between                        $ 28.37                                                                 March 28, 1996, and July 14, 2000 Penalty 163(2)                                        $ 390.26 Interest on this amount between                        $ 240.91                                                                 April 30, 1995, and July 14, 2000 Total                                                        $1,232.78                                 Total interest                                         $ 626.77                                                                                 Grand total for 1994                                                            $1,859.55 [38]          One notes that interest on the unjustified refunds was calculated from March 28, 1996, and that interest on the penalties was calculated from April 30 of each taxation year for which a refund was obtained. ...

Signed at Ottawa, Canada, this 6th day of June 2007.     “Lucie Lamarre” Lamarre J.           ... Counsel for the appellant was able to call instead Daniel Thibault, another collection agent with the CCRA, who was also involved in the appellant’s file in 2002 and has been again since mid‑September 2005, when Mr.  ... Signed at Ottawa, Canada, this 6th day of June 2007.         “Lucie Lamarre” Lamarre J.   ...

The King, 2025 TCC 25 Docket: 2024-463(GST)APP BETWEEN: PASQUALE ZAMPIERI, APPLICANT, and HIS MAJESTY THE KING, Respondent.   ... These deeming provisions are not rebuttable [4]. […] […] [7] The main dispute between the parties regarding these steps is whether the taxpayer’s credibility is to be considered at Step 1 or Step 2. ... Bocock DATE OF ORDER: February 26, 2025 APPEARANCES:   For the Appellant: The Appellant himself Counsel for the Respondent: Benjamin Roizes Ryan Liu   COUNSEL OF RECORD: For the Respondent: Shalene Curtis-Micallef Deputy Attorney General of Canada Ottawa, Canada     [1] Aztec Industries Inc. v. ...

The Queen, 2012 DTC 1154 [at at 3358], 2012 TCC 139 (Informal Procedure)         Docket: 2009-2337(IT)G BETWEEN: JAMES G. ... Costs are awarded to the Respondent.            Signed at Ottawa, Canada, this 30 th day of April 2012.     ... An Equifax Consumer Report dated April 7, 2005 indicated that his address for his credit cards and line of credit was the Belleville Property. ...

Plan Type (check one only):                       ☒ Locked-in RSP/LIRA […] 4. ... Within these required contextual and purposive analyses, mandated by Canada Trustco Mortgage Co v Canada, 2005 SCC 54, lay the requirement of Olympia, as trustee, to pay the uncollected Part I tax of the non-resident vendor (RCI Trust) because Olympia used the trust funds held by it to acquire the trust property in respect of which the Annuitants never had possession or title. ... Pentney Deputy Attorney General of Canada Ottawa, Canada     ...

Therefore, the use of the word “ gift ” in paragraph 110.1(1)(d) does not refer to when an ordinary gift is made, but refers to when an “ ecological gift ” is “ completed ”.   ... R, 2005 SCC 54, at paragraph 10-13, the Supreme Court of Canada noted the following with respect to the principles of interpretation applicable to the Act: 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. ... Visser” Visser J.                             Appendix “A” Statement of Agreed Facts     CITATION: 2019 TCC 178 COURT FILE NO.: 2016-3838(IT)G STYLE OF CAUSE: YELLOW POINT LODGE LTD. ...

The submissions are not to exceed 10 pages.   Signed at Ottawa, Canada, this 27th day of January 2022. ... The bulletin states that the situations or circumstances that may engage subsection 84(2) could include the following: • the funds or property of the transferred corporation are quickly distributed to the estate after the death of the taxpayer; • the shares of the transferred corporation are liquid shares, and the corporation is not engaged in any activity or business. [30] Are the conditions described by the auditor cumulative? ... Hogan DATE OF AMENDED JUDGMENT: January 27, 2022 APPEARANCES: Counsel for the Appellant: Martin Delisle Lisa-Marie Gauthier   Counsel for the respondent: Anne Poirier COUNSEL OF RECORD: For the appellant: Name: Martin Delisle Lisa-Marie Gauthier   Firm: De Grandpré Chait For the respondent: François Daigle Deputy Attorney General of Canada Ottawa, Canada     [1] 2013 FCA 110 (MacDonald). [2] Ibid., paragraph 17. [3] Ibid., paragraph 28. [4] 2021 SCC 49. [5] Ibid., paragraph 1. [6] 2005 SCC 54, [2005] 2 S.C.R. 601. [7] Ibid., paragraph 12. [8] [1942] S.C.R. 269 (Merritt). [9] [1970] S.C.R. 64 (Smythe). [10] [1999] 3 S.C.R. 622. [11] Ibid., paragraph 39. [12] According to the intent of Parliament, there has to be a complete "rollover" at the time of the winding-up. [13] Subsection 104(24) of the Act. [14] Brown v. ...

Polubiec failed to report the following amounts of investment income:   Year   Dividends   Interest Other Income   Miscellaneous s.163(1)(a) Amount             2007 $6,253 $73 $12,317 $630 [6] $12,316 2008 $6,814 $380 $16,447   $23,641 2009 $16,392 $534 $11,394   n/a 2010 $10,935   $8,876 $83 [7] $13,149 2011 $29,159     $122 [8] $20,516 [8]   Mr. ... Polubiec must have failed to report income in one of the three taxation years preceding 2007 (i.e., 2004, 2005 or 2006), otherwise the condition set out in paragraph 163(1)(b) of the ITA would have not have been satisfied for 2007, such that it would not have been possible for the CRA to have assessed a penalty for that year. [10]   Mr. ... See also Knight, supra note 5, ¶2-3, 25 & 30. [61]   Knight, supra note 5, ¶8. [62]   Chan, supra note 46, ¶15. [63]   Norlock, supra note 15, ¶15. [64]   Corporation de l’école polytechnique v The Queen, 2004 FCA 127, ¶29 & 32-38. ...

J.         Signed in Ottawa, on March 20 th, 2009.         IN THE TAX COURT 2007-2665(IT)G 2007-2667(IT)G 2007-2669(IT)G BETWEEN: NIELSEN DEVELOPMENT CO. ... I ask for the court to be adjourned.   (PROCEEDINGS CONCLUDED AT 2:21 P.M.)       ... Beaton       COURT REPORTER         ...