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The actual question (the “ Rule 58 Question ”) reads as follows: Where a trust designates a portion of a taxable dividend (the “ Amount ”) received on a share of the capital stock of a taxable Canadian corporation (the “ Issuer ”), pursuant to subsection 104(19) of the federal Income Tax Act (the “ Act ”), such that the Amount is deemed to have been received by a beneficiary (the “ Beneficiary ”), when is it determined whether the Issuer is connected with the Beneficiary for purposes of paragraph 186(1)(a) of the Act? ... Environmental Ltd. (“ S.O.N.S. ”) brought the required motion requesting a determination, before a hearing, of the Rule 58 Question. ... After hearing from the parties, I issued an order on July 29, 2022 providing for a hearing of the Rule 58 Question (the “ July 29th Order ”). ...

.- INVESCO CANADA FUNDS INCLUDING EACH FUND LISTED IN SCHEDULE "A", Appellant, and   HER MAJESTY THE QUEEN, Respondent,   Docket: 2014-1941(GST)G AND BETWEEN: INVESCO CANADA LTD. / INVESCO CANADA LTÉE, Appellant, and   HER MAJESTY THE QUEEN, Respondent,   Docket: 2014-1943(GST)G AND BETWEEN: INVESCO CANADA MONEY MARKET FUND (FORMERLY AIM CANADA MONEY MARKET FUND) AND EACH OF THE OTHER FUNDS LISTED IN SCHEDULE “B” Appellant,   and HER MAJESTY THE QUEEN, Respondent.   ... The management fee was consideration payable by the Funds to the Manager for the service of funding the deferred sales charge commissions, in addition to the various other management and administrative services provided by the Manager to the Funds under the Management Agreement. [107]    During the period in issue, the Manager reduced the amount of management fees it received from the Funds so that the Earned Daily Fees could be paid to Funding Corp. [108]    The following is written in the Simplified Prospectus dated August 12, 2005 for the Aim and Trimark Funds: “The manager is responsible for the day-to-day business and operations of the Funds and for appointing any sub-advisors. ... SCHEDULE “A” INVESTO CANADA FUNDS CONSOLDIATED GROUP AMOUNTS AT ISSUE     FUND NAME AMOUNT 1. ...

R., 2005 FCA 211 (F.C.A.) (Dynamic Industries). With respect to the history of the relevant provisions of the ITA, Sharlow J.A. observed (at paragraphs 39 and 44): The provisions of the Income Tax Act relating to personal services businesses were enacted to deny certain tax advantages that may be obtained by providing services through a corporation, rather than personally. ... Visser DATE OF JUDGMENT: May 1, 2019   APPEARANCES:   Counsel for the Appellant: Estelle Duez Counsel for the Respondent: Tanis Halpape   COUNSEL OF RECORD: For the Appellant: Name: n/a   Firm: n/a For the Respondent: Nathalie G. Drouin Deputy Attorney General of Canada Ottawa, Canada     [1]   R.S.C., 1985, c.1 (5 th Supp.), as amended. ...

The “before” or Chinese links in that “supply chain” are revealed in the analogous chart below (with descriptions of the primary purpose of each entity in parentheses): The EMI Group                   Incorporated under jurisdictions in Canada                                                                        Incorporated in the British Virgin Islands   (i) Role of the entities [28]          EMI Corp. was the recipient importer of the goods acquired in China, whether intended for charitable or commercial purposes. ... R., 2005 SCR 54 at paragraph 10 directed that a textual, contextual and purposive analysis be used. ... Drouin Deputy Attorney General of Canada Ottawa, Canada     ...

The King, 2024 TCC 28 (Informal Procedure) Docket: 2022-1952(IT)I BETWEEN: MICHELLE ADAMS, Appellant, and HIS MAJESTY THE KING, Respondent.   ... “Joanna Hill” Hill J.   Citation: 2024 TCC 28 Date: 20240307 Docket: 2022-1952(IT)I BETWEEN: MICHELLE ADAMS, Appellant, and HIS MAJESTY THE KING, Respondent. ... In support of this argument, she provided an estimate of time for several activities related to managing and treating her celiac disease through a 100% gluten-free diet: [16] Activity Minutes per week Minutes per day Treatment: consumption of gluten-free foods (3-5 times per day, 7 days per week) 525 75 Treatment: consumption of vitamins/supplements that body can’t absorb due to celiac disease (calcium, B12 and Vitamin D) (Once per day, 7 days per week) 35 5 Preparation of gluten-free foods (3-5 times per day, 7 days per week) 630 90 Communication with people hosting events / preparing food to bring to these events 15 2 Preparation of gluten-free food for family and holiday gatherings (Easter, Thanksgiving, Christmas) 15 2 Communication with family/friends in preparation of gatherings to ensure appropriate food is available 15 2 Self-education and educating others about celiac disease, gluten-free diet, cross-contamination, meal planning, shopping for gluten-free foods, reading labels 20   Communication with restaurants/staff when eating out about gluten-free food options and minimizing cross-contamination 30   Reading labels of food items during each grocery visit to ensure items do not contain barley, rye, oats or wheat (gluten-free) 120   Attending celiac disease workshops (education, cooking, therapy and support) 15   Medical and nutrition appointments and communications 5.76   Medical testing 12.69   Time roommate spends reading labels for food brought into shared living space 60   Total minutes per week managing/treating celiac disease 1498.5   Total hours per week 24.97   [22] As a preliminary issue, Ms. ...

[4]   The following persons testified for Mr. Laplante during the trial:-   Mr.  ... Laplante for the first time in 2005 during the creation of an estate freeze structure using a family trust. ... Pentney Deputy Attorney General of Canada Ottawa, Canada     [1]   Exhibit A-1, Appellant’s Book of Exhibits, Vol. 1, Tab 1, p. 2. [2]   Exhibit A-1, Appellant’s Book of Exhibits, Vol. 1, Tab 1, pp. 7–8. [3]   Exhibit A-1, Appellant’s Book of Exhibits, Vol. 1, Tab 2, pp. 1–2. [4]   Supra, footnote 2. [5]   Exhibit A-1, Appellant’s Book of Exhibits, Vol. 1, Tab 6. [6]   Ibid. [7]   Exhibit A-1, Appellant’s Book of Exhibits, Vol. 1, Tab 5. [8]   Exhibit A-1, Appellant’s Book of Exhibits, Vol. 1, Tab 8. [9]   Ibid. [10]   Exhibit A-1, Appellant’s Book of Exhibits, Vol. 1, Tab 3. [11]   Exhibit A-1, Appellant’s Book of Exhibits, Vol. 1, Tab 4. [12]   Civil Code of Québec, S.Q. 1991, c. 64. [13]   [1999] 3 S.C.R. 622 [14]   Ibid., paragraph 39. [15]   R.S.C. 1985, c. ...

D’Arcy” D'Arcy J.                                   APPENDIX A                                                                                 APPENDIX B                                         Relevant provisions effective to the 2008-09 and 2009-10 reporting periods   Excise Tax Act   Selected listed financial institutions   225.2   (1)  For the purposes of this Part, a financial institution is a selected listed financial institution throughout a reporting period in a fiscal year that ends in a particular taxation year of the financial institution if the financial institution is a listed financial institution described in any of subparagraphs 149(1)(a)(i) to (x) during the particular year and the preceding taxation year and   (a)  the financial institution is a corporation that, under the rules prescribed in any of sections 402 to 405 of the Income Tax Regulations, has or would, if it had taxable income for the particular year and the preceding taxation year, have taxable income earned in the particular year and the preceding taxation year in any of the participating provinces and taxable income earned in the particular year and the preceding taxation year in any of the non-participating provinces;   (b)  the financial institution is an individual, the estate of a deceased individual or a trust that, under the rules prescribed in section 2603 of the Income Tax Regulations, has or would, if it had income for the particular year and the preceding taxation year, have income earned in the particular year and the preceding taxation year in any of the participating provinces and income earned in the particular year and the preceding taxation year in any of the non-participating provinces;   (c)  the financial institution is a specified partnership during the particular year and the preceding taxation year; or   (d)  the financial institution is a prescribed financial institution.   ... APPENDIX C                                         Relevant provisions effective to the 2010-11 reporting period   Excise Tax Act   Selected listed financial institutions   225.2   (1)  For the purposes of this Part, a financial institution is a selected listed financial institution throughout a reporting period in a fiscal year that ends in a taxation year of the financial institution if the financial institution is   (a)  a listed financial institution described in any of subparagraphs 149(1)(a)(i) to (x) during the taxation year; and   (b)  a prescribed financial institution throughout the reporting period.   ...   …     Selected Listed Financial Institutions Attribution Method (GST/HST) Regulations   Interpretation   Definitions   1   (1)  The following definitions apply in these Regulations.   ...

Docksteader 2009 $2,041.20 $3,487.28   2010 $2,167.20 $5,333.70   2011 $2,458.00 $6,652.56   2012 $4,914.40 $13,352.40 Total:   $11,580.80 $28,825.94 Mr. Foran 2009 $4,204.80 $8,817.48   2010 $13,262.40 $28,869.45   2011 $17,206.00 $41,686.22   2012 $9,828.80 $39,084.90 Total:   $44,502.00 $118,458.05 Mr. ... Spiro” Spiro J.   APPENDIX “A”   APPENDIX “B”   APPENDIX “C”     APPENDIX “D”     APPENDIX “E”   APPENDIX “F”     CITATION: 2025 TCC 41 COURT FILE NOS.: 2017‑3467(IT)G 2017-3469(IT)G 2017-3119(IT)G 2017-2987(IT)G 2017-2985(IT)G 2017-440(IT)G STYLES OF CAUSE: NANDAGOPAL AYRE AND HIS MAJESTY THE KING KENNETH COOPER AND HIS MAJESTY THE KING SHARON DOCKSTEADER AND HIS MAJESTY THE KING JAMES FORAN SR. ...

Civiero transferred all of his common shares of Soberlink (the “ Soberlink Shares ”) to Jacal Holdings Ltd. (“ Jacal ”). ... Canada [4] (“ Canada Trustco ”), Lipson v. Canada [5] (“ Lipson ”), Copthorne Holdings Ltd. v. Canada [6] (“ Copthorne ”), Canada v. Alta Energy Luxembourg S.A.R.L. [7] (“ Alta Energy ”) and Deans Knight Income Corp. v. ...

The Queen, 2021 TCC 13 Docket: 2016-4417(IT)G BETWEEN: ADINA GOLDMAN, Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... (ii) By a person who owes an amount under the Act [64] The Appellant accepts that her mother owed in excess of $76,616 in tax in respect of her 2005, 2009 and 2010 tax years. ... Drouin Deputy Attorney General of Canada Ottawa, Canada   [1] Charkaoui v. ...