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  • Saini v. The Queen, 2020 TCC 38

    [1]  The Appellant, Gurpal Saini (“Mr. Saini”) was reassessed arbitrarily by the Minister under subsection 152(7) of the Income Tax Act, RSC 1985, c.1, as amended (the “Act”). The reassessment concerned his 2009, 2010 and 2011 taxation years (the “appeal years”). The Minister asserts Mr. Saini received the following amounts of undeclared income, in the form of shareholder benefits, from 2174

  • Strachan v. The Queen, 2020 TCC 37

    [1]  The Appellant Edward Strachan appeals the Minister of National Revenue’s assessments/reassessments of his 2006, 2007, 2008, 2012, and 2013 taxation years.

  • Sweetman v. The Queen, 2020 TCC 36

    [1]  The Respondent has brought a motion seeking an order pursuant to section 160 of the Tax Court of Canada Rules (General Procedure) (the “Rules”) that the Appellant, Gary Sweetman, pay $19,375 into Court as security for costs in this appeal within 30 days of the date of the order. Mr. Sweetman opposes the order.

  • Zomaron Inc. v. The Queen, 2020 TCC 35

    [1]  Zomaron Inc. (“Zomaron” or the “appellant”) appeals the reassessment and assessment for the periods in issue made by the Minister of National Revenue. The Minister included in Zomaron’s net tax harmonized sales tax collectible on fees it received as consideration for its services in respect of Elavon Canada Company (“Elavon”) and First Data Loan Company, Canada (“First Data”) providing

  • Al-Rubaiy v. The Queen, 2020 TCC 34

    [1]  The Appellant Dr. Al-Rubaiy appeals the Minister of National Revenue’s April 6, 2016 assessment denying his application made under subsection 261(3) of the Excise Tax Act for a rebate of GST/HST paid in error.

  • Burlington Resources Finance Company v. The Queen, 2020 TCC 32

    [1]  The respondent filed a Motion asking the Court to grant leave to file:

  • Hurwitz v. The Queen, 2020 TCC 31

    [1]  The Minister reassessed the Appellant, Mr. Hurwitz, challenging on an alternative basis, each of: the existence of any business (“existence of business”), the business purpose of the expenses (the “business purpose”) and the reasonableness of the expenses (“unreasonable expenses”). The Minister did so in the context of two distinct endeavours undertaken by Mr. Hurwitz in the 2013 and 20

  • 1532099 Ontario Ltd. v. The Queen, 2020 TCC 30

    [1]  The Appellant in this General Procedure matter brings a motion for leave to have its sole director and officer Motlagh Shirazi represent the Appellant in this appeal. The Respondent opposes the Appellant’s motion.

  • Lin v. The Queen, 2020 TCC 26

    [1]  These appeals concern two Asian food restaurants, one in Hamilton and the other in Kitchener, Ontario. The corporate Appellant which operated Hamilton “Sushi Star” was 1647208 Ontario Inc. (“Hamilton Co.”). The corporate Appellant which operated the Kitchener restaurant, “Sushi Stars”, was 1773548 Ontario Inc. (“Kitchener Co.”).

  • Gentile Holdings Ltd. v. The Queen, 2020 TCC 29

    [1]  On June 30, 2015 the Minister of National Revenue (the “Minister”) assessed the Appellant corporation for $116,754.22 (the “Amount”) respecting a transfer of property to it by 0699406 B.C. Ltd. (“0699”) pursuant to subsection 160(1) of the Income Tax Act (the “Act”). This assessment related to an underlying assessment of 0699 for the taxation year ending November 30, 2006. The transfer

  • Callaghan v. The Queen, 2020 TCC 28

    [1]  During the 2008 to 2014 taxation years the Appellant’s claimed business losses in relation to a partnership. The Minister denied the losses.

  • Dreger v. The Queen, 2020 TCC 25

    [1]  The Minister assessed each of the Appellants $96,640.96 under section 160 of the Income Tax Act in respect of monies they each received as the named beneficiaries of a life income fund. The late father of each of the Appellants, Frederick R. Baglole, was the annuitant of the fund.

  • Hamilton v. The Queen, 2020 TCC 23

    [1]  The Appellant was reassessed for his 2014 and 2015 taxation years on March 5, 2018 and June 29, 2018 respectively. These reassessments included in his income total benefit amounts of $13,128.01 in the 2014 taxation year and $8,807.90 in the 2015 taxation year in respect to travel and overtime meal allowances conferred on him in his capacity as an employee of CIMS Limited Partnership (th

  • White v. The Queen, 2020 TCC 22

    [1]  These appeals raise the issue of whether the deposit of funds by a person into a bank account that is held jointly with the person’s spouse constitutes a transfer of property for the purposes of section 160 of the Income Tax Act and section 325 of Part IX of the Excise Tax Act (the “GST Act”).

  • Dutka v. The Queen, 2020 TCC 21

    [1]  Terri Dutka (the Applicant) has applied for an extension of time to institute an Appeal from the reassessment of her 2011 and 2012 taxation years pursuant to section 167 of the Income Tax Act (the “ITA”).

  • Galvis v. The Queen, 2020 TCC 20

    [1]  The Appellant, Mauricio Galvis (MG), appeals two reassessments raised September 25, 2017 by the Minister of National Revenue (Minister) under the federal Income Tax Act (ITA) regarding MG’s income tax liabilities for his 2014 and 2015 taxation years. Both reassessments disallowed employment expenses claimed in relation to usage of a 2011 Mercedes Benz automobile and as well disallowed...

  • 9267-2245 Quebec Inc. v. M.N.R., 2020 TCC 10

    [1]  The Appellant appeals a decision of the Minister of National Revenue (the "Minister") under the Employment Insurance Act, S.C. 1996, c. 23 (the "EIA"), regarding the insurability of the employment with the Appellant of Shariff Mohammed, Michel Nolet and Alain Vandette (the “drivers” ) for the period starting January 1st, 2017 and ending February 26, 2018 (the “period

  • Ampratwum-Duah v. The Queen, 2020 TCC 18

    [1]  Rev. Augustine Ampratwum-Duah, the Appellant, appeals three reassessments concurrently raised December 29, 2017 pursuant to the federal Income Tax Act (ITA) respecting his 2005, 2006 and 2007 taxation years. Specifically, the appeal pertains to denial of claimed charitable donations for those years. The initial assessments had been concurrently raised August 9, 2010, and were objected...

  • CHR Investment Corporation v. The Queen, 2020 TCC 17

    [1]  The Applicant (Appellant) (hereafter, Appellant), CHR Investment Corporation has brought an interlocutory motion pursuant to section 110 of the Tax Court of Canada Rules (General Procedure), for an order that the Respondent Crown answer six underlying undertaking requests made by the Appellant in the course of its discovery examination of the Respondent. The Respondent took each of...

  • Lilyfield Development Inc. v. The Queen, 2020 TCC 16

    [1]  The Respondent has brought a Motion to Quash the Appeal of the Appellant. The basis for this request is that the Appellant, which is a dissolved corporation, lacked the capacity either to initiate the Appeal, or to take any action within the Appeal. [1]

  • Tudora v. The Queen, 2020 TCC 11

    [1]  The Appellant has appealed his reassessment from the Minister of National Revenue (the “Minister”) in respect of his 2005 taxation year. The Appellant is disputing the Minister’s denial of his claim for charitable tax credits pursuant to section 118.1 of the Income Tax Act (the “Act”). Specifically, the amounts the Appellant claims to have gifted in the 2005 taxation year are a $5000...

  • Univar Holdco Canada ULC v. The Queen, 2020 TCC 15

    [1]  The Applicant, Univar Holdco Canada ULC (“Univar”) has brought a motion to have costs determined in accordance with Rule 147. The parties agreed to have this decided based upon their written submissions and the evidence submitted on this motion.

  • Gilao v. The Queen, 2020 TCC 14

    [1]  The Appellant, Mr. Gilao, has not filed income tax returns for the 2011, 2012 and 2013 taxation years (the “appeal years”). As a result, the Minister assessed Mr. Gilao for those years under section 152(7) of the Income Tax Act, RSC 1985, c.1, as amended (the “ITA”). The Minister also levied failure to file penalties and assessed arrears interest on the unreported income for the appeal

  • Peach v. The Queen, 2020 TCC 12

    [1]  Harold Peach lives in Salmon Cove, Newfoundland and Labrador. In 2011, he owned several properties that he rented to his sons. He also tried to sell life insurance and mutual funds under the name Harold’s Financial Services (“HFS”). In 2011, Mr. Peach claimed significant losses associated with these two activities. He also transferred one of his rental properties to a son. However, he...

  • Muir v. The Queen, 2020 TCC 8

    [1]  This informal appeal is from a section 160 assessment of the Appellant in respect of an amount transferred to her by a corporation of which she was the sole shareholder and director.

  • Krumm v. The Queen, 2020 TCC 7

    [1]  On August 1, 1997, during what is often referred to as the dot-com boom or the tech bubble, Mr. Krumm entered into an Asset Purchase Agreement pursuant to which he purchased a 50% interest in computer application software (the “Software”) owned by Intersports Acceleration Corp. (“IAC”) for $2.8 million, of which $700,000 was payable by cheque and $2.1 million was payable by way of Long

  • Morriseau v. The Queen, 2020 TCC 5

    [1]  These Reasons pertain to the Appeals of Christopher Morriseau and Miranda Smoke from reassessments made by the Canada Revenue Agency (the “CRA”), on behalf of the Minister of National Revenue (the “Minister”), for the 2012 and 2013 taxation years. For each of those years, Mr. Morriseau and Ms. Smoke, who are registered as Indians [1] for the purposes of the Indian Act, [

  • Scott v. The Queen, 2020 TCC 4

    [1]  This is an appeal by John Randall Scott (the “Appellant”) from an assessment issued by the Minister of National Revenue (the “Minister”) under subsection 160(1) of the Income Tax Act in the circumstances described immediately below.

  • Bosveld v. M.N.R., 2020 TCC 2

    [1]  At the outset, the parties agreed that all appeals be heard together. In addition, the Crown submitted that credibility with not an issue. I agree.

  • Cassidy v. Canada (Employment and Social Development), 2020 TCC 1

    [1]  Frank Cassidy (“Mr. Cassidy”) has appealed the decision of the Minister of Employment and Social Development (the “Minister”) regarding the calculation of his Guaranteed Income Supplements benefits (“GIS”) under the Old Age Security Act, R.S. 1985, c.O-9  (the “OAS”) for the payment period of July 2018 to June 2019. Specifically at issue is what the Appellant’s income was for the purposes...

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