Concept
Professional History
Deyab v. Canada, 2020 FCA 222 / I. Background
"Mr. Deyab is an industrial engineer. For a number of years he worked for Maple Leaf Meats and its predecessor corporations. He eventually became the director of engineering for that company. In 2000, he left the employment of Maple Leaf Meats and he received a severance payment of $1,000,719.\n\nPrior to his leaving Maple Leaf Meats, Mr. Deyab and his spouse incorporated a numbered company for the purpose of carrying on certain engineering consulting work. After he left Maple Leaf Meats, Mr. Deyab, through the numbered company, provided engineering consulting work to Furlani’s Food Corporation and Whyte’s Food Corporation Inc. starting in 2001.\n\nOn December 1, 2005, Mr. Deyab formed M.D. Consulting 2005 Inc. (M.D. Consulting), which is the relevant corporation in this appeal. This corporation continued to carry on consulting work for Furlani’s Food Corporation and other clients. Mr. Deyab testified that his net worth in 2000 was approximately $3 million to $4 million. A letter from BMO Harris Private Banking dated November 21, 2014 confirmed that the numbered company, as of September 20, 2005, had a balance in its account of $4,222,542. Mr. Deyab testified that when he started M.D. Consulting, he transferred everything from the numbered company to this company."
Related Ideas
- Source EvidenceDeyab v. Canada, 2020 FCA 222 · A. Burden of Proof
- Shareholder BenefitsDeyab v. Canada, 2020 FCA 222 · II. Decision of the Tax Court
- Loan RecordsDeyab v. Canada, 2020 FCA 222 · A. Burden of Proof
- Loan ReconciliationDeyab v. Canada, 2020 FCA 222 · B. Adverse Inference
- Statute-barred YearsDeyab v. Canada, 2020 FCA 222 · II. Decision of the Tax Court
- ReassessmentsDeyab v. Canada, 2020 FCA 222 · Case tabs
- Amounts DisputedDeyab v. Canada, 2020 FCA 222 · I. Background
- Tax LiabilityDeyab v. Canada, 2020 FCA 222 · A. Burden of Proof