Date: 20191205 Docket: A-416-18 Citation: 2019 FCA 303 [ENGLISH TRANSLATION] CORAM: NADON J.A. BOIVIN J.A. LOCKE J.A. BETWEEN: GONUL ERMIS Appellant and HER MAJESTY THE QUEEN Respondent Heard at Montréal, Quebec, on December 5, 2019. Judgment delivered from the bench at Montréal, Quebec, on December 5, 2019. REASONS FOR JUDGMENT OF THE COURT BY: BOIVIN J.A. Date: 20191205 Docket: A-416-18 Citation: 2019 FCA 303 CORAM: NADON J.A. BOIVIN J.A. LOCKE J.A.

BETWEEN: GONUL ERMIS Appellant and HER MAJESTY THE QUEEN Respondent REASONS FOR JUDGMENT OF THE COURT (Delivered from the bench at Montréal, Quebec, on December 5, 2019) BOIVIN J.A. [ 1 ] Without commenting on the remarks of the Associate Chief Justice of the Tax Court of Canada (TCC) regarding this Court’s decision in Loates ( Loates v. Canada , 2016 FCA 47 ), we are of the opinion that she made no reviewable error in holding that there was a transfer of property within the meaning of

section 325 of the Excise Tax Act , R.S.C. 1985, c. E-15 to the Appellant by her spouse. Furthermore, the evidence in support of the consideration that the Appellant allegedly gave to her spouse appears to us to be clearly insufficient. [ 2 ] Since we agree with the findings of the Associate Chief Justice of the TCC and we adopt in substance her reasoning, there is no need for us to add anything to her reasons.

[ 3 ] The appeal will therefore be dismissed with costs. “Richard Boivin” J.A. Certified true translation Erich Klein FEDERAL COURT OF APPEAL SOLICITORS OF RECORD Docket: A-416-18 STYLE OF CAUSE: GONUL ERMIS v. HER MAJESTY THE QUEEN PLACE OF HEARING: Montréal, Quebec DATE OF HEARING: December 5, 2019 REASONS FOR JUDGMENT OF THE COURT BY: NADON J.A. BOIVIN J.A. LOCKE J.A. DELIVERED FROM THE BENCH BY: BOIVIN J.A. APPEARANCES : Henri Simon FOR THE APPELLANT Marie-Pier Lauzon-Raza FOR THE RESPONDENT SOLICITORS OF RECORD : SimonLegal, S.A. Montréal, Quebec FOR THE APPELLANT Nathalie G. Drouin Deputy Attorney General of Canada Ottawa, Ontario FOR THE RESPONDENT