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TCC

Yevzeroff v. The Queen, 2013 TCC 268 (Informal Procedure)

“commercial activity” of a person means   (a) a business carried on by the person (other than a business carried on without a reasonable expectation of profit by an individual, a personal trust or a partnership, all of the members of which are individuals), except to the extent to which the business involves the making of exempt supplies by the person, (b) an adventure or concern of the person in the nature of trade (other than an adventure or concern engaged in without a reasonable expectation of profit by an individual, a personal trust or a partnership, all of the members of which are individuals), except to the extent to which the adventure or concern involves the making of exempt supplies by the person, and (c) the making of a supply (other than an exempt supply) by the person of real property of the person, including anything done by the person in the course of or in connection with the making of the supply;                                                                                              [My emphasis ...
TCC

C.P.B. v. The Queen, 2013 TCC 118 (Informal Procedure)

., the Appellant, appeals by way of Informal Procedure the Minister of National Revenue’s (the "Minister") denial of the Canada Child Tax Benefit ("CCTB") for her in connection with her daughter for the 2010 base taxation year. ...
TCC

ACI Properties Ltd. v. The Queen, 2013 TCC 101

In short, the now dated and spent review has no connection to “the context or in pursuance of a proposed reassessment” as detailed in Daruwala and Brenneur ...
FCTD

Livingston International Inc. v. Canada (Minister of National Revenue), docket T-1953-87

Justice Rand stated, at p. 726: No doubt there is in fact a causal connection between the purchase of the stock and the benefits ultimately received; but the statutory language cannot be extended to such a remote consequence; it could be carried to any length in a chain of subsidiaries; and to say that such a thing was envisaged by the ordinary expression used in the statute is to speculate and to interpret. ...
FCTD

Canada (Minister of National Revenue) v. McMordie, 2006 FC 209

The Respondent's failure was by not having provided a list of all of the Canadian and foreign institutions which held accounts for which he had signing authority or power of attorney and, in connection therewith, the account holders, the account numbers and the dates the accounts were opened and closed as well as a list of the names of the credit cards, the names of the issuers of those cards, their account numbers that were in his name, in the name of his business or in which the Respondent was a joint holder. [7]                The Respondent testified to the effect that he had substantially complied with the order because if one examined his several responses and his final response on April 16, 2005, the banks were identified as well as the credit cards and their issuers. [8]                However, in argument, he admitted his responses lacked several details which he was required to provide. [9]                Based on the evidence before me and the Respondent's admission I am satisfied beyond a reasonable doubt that the Respondent is guilty of contempt by failing to wholly provide the Minister the information/documents spelled out in items 2 and 4 of counsel to the Minister's letter of February 23, 2004, to Justice MacKay and which were the acts specified in Prothonotary Lafrenière's Show Cause Order of December 19, 2005. [10]            The penalty which the Court may impose on a finding of contempt is spelled out in Rule 472 which reads: 472. ...
FCTD

Canada (Canada Customs and Revenue Agency) v. Sherman, 2006 FC 192

Accordingly, I am convinced this is not a case where I should decline to exercise my discretion. [9]                It is perhaps of some significance that in early 2000 the Respondent initiated a complaint to the Canadian Human Rights Commission (Tribunal) in connection with her treatment by the CCRA with particular reference to the issues of accommodation and termination. ...
FCTD

Ross v. Canada (Canada Customs and Revenue Agency), 2006 FC 1391

(Bruce Ross admitted he did not in connection with this exchange say that his wife also had a declaration to make:  see transcript, page 26, and she testified she said nothing at this time:  see transcript pages 37-38.)  ...
FCTD

Alex Parallel Cmputers Research Inc. v. Canada, docket T-1512-97

Article 5.2 of this research agreement provided that in consideration for the research activity conducted by the University of Ottawa, APCR would pay $2,944,482.93 to the University, in 24 equal monthly payments of $122,686.79, from March 1993 to March 1995. [3] On or about August 31, 1994, Revenue Canada began to audit APCR's tax return for its 1993 taxation year with regard, inter alia, to the investment tax credits claimed by APCR for scientific research and technical development expenditures incurred in connection with the research agreement. ...
FCTD

1185740 Ontario Ltd. v. Canada (Minister of National Revenue), docket T-384-98

the complete record, being copies of all decisions, records of meetings, briefing notes, analysis, correspondence within, to and from the Government of Canada, including within, to and from Ministers, officials, exempt staff and ministerial aides, Members of Parliament and Senators, in connection with the proposed sale of duty free gas at land border crossings by licenced duty free shops (the "Documents") including all Documents connected with representations made by the University of Windsor, The Canadian Transit Company, The Frontier Association, 1185740 Ontario Limited and Johnstown Duty Free Shop Inc. and other Duty Free Shops, local governments, businesses and politicians and their advocates and counsel for the period from November 1, 1995 to February 24, 1998; and              B.      ...
FCTD

Munzel v. Canada, docket T-1045-98

While setting out a number of examples, and a good deal of case law in his Statement of Claim, the Plaintiff does touch on his connection to these allegations by pleading that he is a pensioner of a chartered bank. ...

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