Tax Court (Canada)

[1] This is an appeal by C&W Offshore Ltd. (“C&W Offshore”) from reassessments issued by the Minister of National Revenue (the “Minister”) in respect of its 2014 and 2015 taxation years.

[1] The Appellant challenges an assessment issued under the Excise Tax Act (the “Act”). Although the assessment allowed a rebate of GST/HST paid in error of $240,000 under subsection 261(1) of the Act, it denied a rebate of GST/HST paid in error of $83,850 under subsection 261(3) of the Act. The Appellant appeals the denial of that portion of its rebate application.

[1] This case involves a determination whether a claim by the representative of a corporation who was credible in his testimony as to the transmission of a Notice of Objection (or of its functional equivalent) was also reliable in this respect, in light of the relative paucity of documentation supporting his solemn affirmation that he had communicated with the Tax Court of Canada.

[1] The Applicant in File No. 2024-1977(GST)APP, Ms. Karima Alarakhia, is a self-represented party who sought an Order from the Court granting her an extension of time within which to file an Appeal in respect to a decision by the Canada Revenue Agency to disallow her entitlement to the GST/HST New Housing Rebate. The Notice of Re-Assessment is dated September 20, 2020, and resulted in a balance...

[1] The Appellant appeals a Notice of Determination denying the Canada Emergency Wage Subsidy (the “CEWS”) for the qualifying periods from March 15, 2020 to April 11, 2020, April 12, 2020 to May 9, 2020, May 10, 2020 to June 6, 2020, June 7, 2020 to July 4, 2020 and July 5, 2020 to August 1, 2020 (the “Periods”, and, individually, Periods 1 to 5 respectively).

[1] The Respondent seeks an order compelling answers to four questions posed at the examination for discovery of Gabrijel Culig. Counsel for the Appellants undertook to answer those questions. Five business days before the deadline for answering undertakings, counsel for the Appellants advised that the questions would not be answered.

[1] Although Peloton is a well-known brand name, it is also a common word for the main throng of riders in a bicycle race, who ride close together to lessen wind drag by following in the leaders’ slipstream – a practice called drafting. This works until the end of the race, when co-operation yields to a sprint towards glory or, at least, respectability.

[1] The present motions are the result of too many delays that provided the Respondent with too much time to reconsider its position and reconsider it again. The appeals were filed in 2016, delayed by a bifurcation application in 2018, then held in abeyance in 2021 pending a Federal Court of Appeal decision in similar matters.

[1] The Appellants herein (the Theta King Appellants or the Appellants and the Theta King Appeals as the context requires) are all subject to a Case Management Order issued by St-Hilaire CJ on November 16, 2025 (the CM Order).

[1] This motion is the result of a last-minute request on behalf of the appellant for me to take judicial notice of a document, after the evidence portion of this appeal had closed.

[1] Mr. Talukdar appeals by way of the informal procedure, an assessment (the “Assessment”) by the Minister of National Revenue (the “Minister”), denying him the Goods and Services Tax/Harmonized Sales Tax (“GST/HST”) New Housing Rebate (the “Rebate”) available under Part IX of the Excise Sales Tax (the “Act”). The amount of the Rebate adjustment at issue is $22,593.31. The appeal arises from the

[1] The Appellant, Ms. Ginevro is the mother of two children H, born in 2012, and T, born in 2019. Ms. Ginevro and the children’s father, Marcus Vinicius Veri Teixeira, married in Brazil in 2010 and moved to Canada in 2015. They separated in February 2021 and ultimately divorced in 2023.

[1] These two appeals were heard on common evidence. The two appellants, Dustin Caddell and Breanne Caddell, are each other’s spouse. On August 4, 2023, the Minister of National Revenue (Minister) reassessed each for GST/HST liability under the Excise Tax Act (Act) for self-supply of a new residence. The two substantively identical reassessments are individually appealed.

[1] The reasons below are issued following my Order of January 28, 2026 as amended on January 29, 2026. That Order dismissed the Proposed Participant’s request to be a party to the appellants’ motion set for hearing on February 10, 2026 to designate the appeal of David Hawreluk v His Majesty the King, 2023-2276 as a lead case for the appellants herein which, Order indicated that reasons were to...

[1] The Appellants, Japseet Kaur Gill and Harman Singh Gill, appeal from assessments, dated November 6, 2012, made under section 160 of the Income Tax Act (“Act”). The underlying tax liability for the assessments is that of Maninder Gill. The appeals were heard on common evidence.

[1] The appellant, Ms. Barbara Marleau, appeals fourteen reassessments, respecting her 1997 to 2010 taxation years. The Minister of National Revenue (Minister) raised each of these reassessments on October 13, 2016 under the federal Income Tax Act (Act)[1]. Each reassessment was raised beyond its normal reassessment period, being three years from date of original assessment. Thus, pursuant to...

[1] The Respondent has brought a motion under section 69 of the Tax Court of Canada Rules (General Procedure) (the “Rules”) for an order striking portions of the Appellant’s Fresh Amended Notice of Appeal, with costs, on the basis that they disclose no reasonable grounds for appeal pursuant to paragraph 53(1)(d) of the Rules.

[1] These reasons concern two motions: one by the Respondent, and one by the Appellant.

[1] John Doe worked for RBC Dominion Securities in Vancouver, British Columbia, until July 9, 2015.[1]

[1] This is an application brought by Terrence D. Tolley under section 166.2 of the Income Tax Act (the “Act”) to extend the time for filing a notice of objection to reassessments issued with respect to the 2011, 2012 and 2013 taxation years. All statutory references herein are to the Act, unless otherwise indicated.

[1] Cineplex Inc. (the “Appellant”) is appealing from a reassessment (the “Reassessment”) in respect of its 2014 taxation year in which the Minister of National Revenue (the “Minister”) disallowed the deduction of $26,510,522 of non-capital losses.

[1] The Applicant seeks two orders in this motion. First, that I recuse myself as case management judge, and a different judge, who has never worked for the Department of Justice, be appointed. Secondly, an order that the Crown provide Mr. King with funds to finance the litigation.

[1] The appellant is a software development company based in Edmonton and specializing in industrial automation.

[1] The Appellant, Anastase Maragos, was a director of Salmon’s Linen Supply Inc. (“SLS”). SLS was incorporated under the Canada Business Corporations Act (the “CBCA”).

[1] The Respondent[1] moved for leave to file Amended Amended Replies under Rule 54 of the Tax Court of Canada Rules (General Procedure)[2] (the “Rules”) in Court files 2021-994(IT)G (“2012 Appeal”) and 2021-2721(IT)G (“2013 Appeal”). In both matters, the assessments relied on the recharacterization rule in s. 247(2)(b) and (d) of the Income Tax Act (Canada)[3] to deny deductions of amounts...

[1] The appellant operates a fastener manufacturing business. This appeal concerns a bank deposit analysis that was undertaken by the Canada Revenue Agency (CRA) regarding the appellant’s taxation years ending December 31, 2013, and December 31, 2014. As part of the analysis, the CRA converted amounts that were deposited in foreign currency accounts into Canadian currency. In the end, the CRA...

[1] This is an appeal of a reassessment under the Income Tax Act (the “Act”) for the 2007 taxation year in respect of a credit claimed by the Appellant[1] for a donation in kind of certain licences (the “Licences”) to a charitable organization.

[1] The issues in this appeal are whether the Appellant, an Uber driver, was required to remit HST of $1,251.11 and $7,319.47 for the yearly reporting periods ending December 31, 2015 and December 31, 2016 respectively on amounts paid for rides provided by him via the Uber application (the “Uber App”) and, if so, whether the Appellant is entitled to input tax credits (“ITCs”) for taxes paid in...

[1] The Respondent brought a motion to compel answers to questions arising from undertakings made at the examinations for discovery of each of the two Appellants.

[1] The Respondent brings a motion to strike the Appellant’s pleading filed in response to the Respondent’s Reply for failure to comply with the Tax Court of Canada Rules (General Procedure) (“Rules”). The Appellant disputes that his pleading is not compliant.