Chad v. The Queen,
| Jurisdiction | Federal Jurisdiction (Canada) |
| Neutral Citation | 2021 TCC 45 |
| Court | Tax Court (Canada) |
| Date | 29 July 2021 |
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5 practice notes
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Canada v. Preston, 2023 FCA 178
...assumption does not cast an onus on [a taxpayer] just because it was pleaded” (at paras. 67-68). See also Chad v. The Queen, 2021 TCC 45 at para. 44; Gerbro Holdings Company v. Canada, 2016 TCC 173 at para. 67, aff’d Canada v. Gerbro Holdings Company, 2018 FCA [21] The respond......
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Hillcore Financial Corporation v. The King, 2023 TCC 71
...to the effect that documents or contracts were “sham”, which is a conclusion of law. As stated by this Court in Chad v. R, 2021 TCC 45 [Chad]: …the factual underpinnings (such as intention to mislead) may be pleaded as facts assumed by the Minister but the mention or us......
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Chad v. The King, 2023 TCC 76
... [1] Those two Impugned Provisions are paragraph 5.1 and subparagraph 5.2(b) of the Second Amended Reply. [2] Chad v. The Queen, 2021 TCC 45. [3] Affidavit of Stephanie Bourgon (the “Affidavit”), filed September 27, 2021. [4] Affidavit, ¶12. [5] British Columbia (Mi......
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Cote Estate v. The King, 2023 TCC 66
...paragraphs 18.175 to 18.190, these paragraphs all deal with the purported sham. I am satisfied based on the decision in Chad v. The Queen (2021 TCC 45) that these paragraphs have been appropriately pled. [39] The phrase, “in the sham,” appears in paragraph 18.191. This is an i......
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5 cases
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Canada v. Preston, 2023 FCA 178
...assumption does not cast an onus on [a taxpayer] just because it was pleaded” (at paras. 67-68). See also Chad v. The Queen, 2021 TCC 45 at para. 44; Gerbro Holdings Company v. Canada, 2016 TCC 173 at para. 67, aff’d Canada v. Gerbro Holdings Company, 2018 FCA [21] The respond......
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Hillcore Financial Corporation v. The King, 2023 TCC 71
...to the effect that documents or contracts were “sham”, which is a conclusion of law. As stated by this Court in Chad v. R, 2021 TCC 45 [Chad]: …the factual underpinnings (such as intention to mislead) may be pleaded as facts assumed by the Minister but the mention or us......
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Chad v. The King, 2023 TCC 76
... [1] Those two Impugned Provisions are paragraph 5.1 and subparagraph 5.2(b) of the Second Amended Reply. [2] Chad v. The Queen, 2021 TCC 45. [3] Affidavit of Stephanie Bourgon (the “Affidavit”), filed September 27, 2021. [4] Affidavit, ¶12. [5] British Columbia (Mi......
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Cote Estate v. The King, 2023 TCC 66
...paragraphs 18.175 to 18.190, these paragraphs all deal with the purported sham. I am satisfied based on the decision in Chad v. The Queen (2021 TCC 45) that these paragraphs have been appropriately pled. [39] The phrase, “in the sham,” appears in paragraph 18.191. This is an i......
Request a trial to view additional results