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The King, 2023 TCC 52 (Informal Procedure) Docket: 2013-3259(IT)I BETWEEN: SEAN O'HAGAN, Appellant, and HIS MAJESTY THE KING, Respondent.   ... Russell” Russell J.   Citation: 2023 TCC 52 Date: May 2, 2023 Docket: 2013-3259(IT)I BETWEEN: SEAN O'HAGAN, Appellant, and HIS MAJESTY THE KING, Respondent.   ... In this matter a deduction of $308,073 was claimed, with a loss carryback request that would have allowed for refund of the taxpayer’s entire tax for the years 2005 to 2008. ...

For 2011 Schedule II (Balance Sheet – Liabilities): add a loan from Mr. ... He for the purchase of a property located at 9 Fulham Street (the “Fulham Property”) should be taken into account, and various adjustments should be made to the value of the shareholders’ loan account of Seasons. · Investment of $46,275 in the Splendid China Square Property [88] In 2005, Mr. ... Piccolo   Firm: TaxChambers LLP Toronto, Ontario For the Respondent: Shalene Curtis-Micallef Deputy Attorney General of Canada Ottawa, Canada   ...

The King, 2023 TCC 140 Docket: 2018-1078(GST)G BETWEEN: FIERA FOODS COMPANY, Appellant, and HIS MAJESTY THE KING, Respondent.   ... Services provided – Temporary General Production Labour, last day of Interactions September 7, 2012. ... Canada, 2005 SCC 54, [2005] 2 S.C.R. 601, at para. 10). In the taxation context, a “unified textual, contextual and purposive” approach continues to apply (Placer Dome Canada Ltd. v. ...

The King, 2025 TCC 23 Docket: 2021-2686(IT)G 2022-2715(IT)G 2022-2717(IT)G BETWEEN: CAMECO CORPORATION, Appellant, and HIS MAJESTY THE KING, Respondent.   ... MacPhee” MacPhee J.   Citation: 2025 TCC 23 Date: 20250211 Docket: 2021-2686(IT)G 2022-2715(IT)G 2022-2717(IT)G BETWEEN: CAMECO CORPORATION, Appellant, and HIS MAJESTY THE KING, Respondent. ... Rule 170.1 Order [67] Rule 170.1 allows a party to apply for a judgment at any stage in the proceeding when there are no facts or legal issues in controversy. [45] Chief Justice Bowman hypothesized that the purpose of Rule 170.1 is to permit the court to grant “ pro tanto ” judgments in cases in which multiple issues are raised and the Crown is prepared to consent to judgement on one issue, so that a relieving reassessment can be issued and the parties can litigate the remaining issues. [46] A. ...

In September 2005, he participated in another chess tournament in Québec. In the fall of 2005, he spent a lot of time playing video games and chess. ... For the respondent: François Daigle Deputy Attorney General of Canada Ottawa, Canada   ...

Canada, 2005 SCC 8, [2005] 1 S.C.R. 113 at par. 7 and 15 and Imperial Tobacco Canada Ltd. v. ... Sekhon, [2014] 1 S.C.R. 272). [62]         I overruled that objection. ... Pentney Deputy Attorney General of Canada Ottawa, Canada                       [1]           Professor Thornton said that "[t]he requirement to declare the intention to use hedge accounting in advance precludes...   ...

.: — This is an appeal from an assessment respecting the 1989 taxation year notice of which was sent to the appellant on June 12, 1990. ... In Exhibit A-l, the appellant also filed a document entitled “Schedule I” in which he established the sum of the amounts actually paid to his ex-wife in 1989 and the sum of the amounts which he allegedly paid for her for the children’s benefit and which he said he deducted from the amounts which he had had to pay her as support in 1989.1 reproduce this schedule below: SCHEDULE 1 Payments/Deductions Made MONTH: DEDUCTIONS: PAYMENT January 8, 1989: $1,000: 0 February, 1989: $ 377.66: $ 622.34 March, 1989: $ 717.75: $ 282.25 April, 1989:$ 29.87: $ 970.13 May, 1989:$ 14.87: $985.13 June, 1989:$ 29.75: $ 970.25 TOTAL: $2,169.90: $3,830.10 It is this amount of $2,168.90 which the appellant claimed as a deduction in addition to the amount of $3,830.10 in support for the 1989 taxation year. ... Minister of National Revenue, [1990] 2 C.T.C. 2005, 90 D.T.C. 1499. He had to determine whether the deduction claimed for alimony by the appellant Poliquin in computing his income from the sum which he should have paid in alimony to the appellant Miss Blais, but which, according to the appellant Poliquin, had been applied to reduce a claim which he had against his former wife, was valid under paragraph 60(b) of the Act. ...

The Statutory Scheme [5] [8]              The relevant provisions are in sections 118.3 and 118.4 of the Income Tax Act (“ Act ”); they are reproduced in annex A of these reasons. ... Paragraph (d) excludes from the 14‑hour average any time spent on: –        dietary restrictions or regimes, –        travel time, –        medical appointments and –        shopping for medication. [37]         In my view, medical appointments in paragraph 118.3(1.1)(d) include meetings with doctors and other health professionals but do not include a medical appointment where there is more than a meeting or discussions with the professional. ... THE QUEEN   DATE OF HEARING: February 20, 2017   DATE OF RECEIPT OF TRANSCRIPT OF HEARING: March 7, 2017   REASONS FOR JUDGMENT BY: The Honourable Justice Gaston Jorré   DATE OF JUDGMENT: July 10, 2017   DATE OF AMENDED REASONS FOR JUDGMENT: July 20, 2017   APPEARANCES:   Agent for the Appellant: Norman John Adams Counsel for the Respondent: John Maskine COUNSEL OF RECORD:   For the Appellant:   Firm:   For the Respondent: Nathalie G. ...

Use of Losses [55] The Appellant used non-capital loss carryforwards and net capital loss carryforwards from its mining activities to reduce its income and capital gains from its real estate business by the following amounts in the following years: Tax Year Ending Non-Capital Loss Carryforwards Claimed Net Capital Loss Carryforwards Claimed December 31, 1998 $418,016   December 31, 1999 $1,082,910   December 31, 2000 $2,256,375 $347,133 December 31, 2001 $2,976,801 $1,705,743 December 31, 2002 $1,199,429 $4,151,138 December 31, 2003   $254,594 December 31, 2004 $2,437,465 $1,341,068 December 31, 2005 $2,540,311 [14] $546,877 December 31, 2006   $9,478,309 December 31, 2007   $13,200,287 December 31, 2009 $7,539,680 December 31, 2011   $1,156,686 August 31, 2013   $3,773,141   [56] Only the last three taxation years are before me. ... Davies   Firm: Thorsteinssons LLP For the Respondent: Shalene Curtis-Micallef Deputy Attorney General of Canada Ottawa, Canada   [1] Copthorne Holdings Ltd. v. ... The percentage is calculated as follows: 6.02% = (6,700,000 / [6,700,000 + 1,600,000 + 102,994,839]). [3] I had difficulty with parts of Mr. ...

“Réal Favreau” Favreau J.       Docket: 2013-1220(EI) BETWEEN: KELLY GODIN, Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent.   ... Godin submitted the following documents: −          the registration of his three boats used for fishing lobster and herring; −          invoices for the delivery of baits to the Arseneau Fish Market which show that he was in operation during the month of April of each year; −          the truck inspection reports showing that he had six or seven trucks in 2007; −          a map showing from where he purchased crabs; −          receipts from Arseneau Fish Market showing trips made by Lucien Carrier; −          purchase and sale of lobsters by Jacques Doucet; −          the timesheets prepared by Tracy Esliger; −          payments for the purchases of lobster for three years; −          T-4 slips prepared by Tracy Esliger issued to crab fishermen; −          receipts for wood delivered to Bathurst in 2010 but cut in 2009; −          receipts from the Arseneau Fish Market showing that he was still in operation during the month of July of each year. [20]         Every April, Mr. ... McIntyre For the Intervenor: The Intervenor herself   COUNSEL OF RECORD: For the Appellant: Name:     Firm:   For the Respondent: William F. ...