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Miller J stated: … It is my view that in a GAAR appeal, draft documents prepared in the context of a taxpayer’s audit or considered by officials involved in or consulted during the audit and assessment of the taxpayer should be disclosed. ...

. … I have no jurisdiction to decide a matter of consequence to taxpayers that are not appellants before this Court. ...

This principle was recognized… in Huntley … 2010 TCC 625, at paragraph 17. ...

., – who also thereupon became member of the Appellant, along with the Canadian and U.S. ...

He also found that providing the ½ deduction under s. 110(1)(d) to the taxpayers accorded with the broader context of the stock option rules. ...

On this basis, she found (at para 35): … The supply of orthodontic treatments were dental services, consisting of a supply of consultative, diagnostic, treatment or other health care services rendered by a medical practitioner to patients and as such are exempt supplies within the parameters of section 5 of Schedule V, Part II. ...

University Hospitals Board, 2006 ABCA 101, 384 A.R. 23, the majority of the Alberta Court of Appeal stated that: … Where a settlement offer does not contain an element of compromise, the court may nevertheless consider it to have been reasonable in the circumstances and exercise its discretion to award enhanced costs. ...

Ahmad instead appealed the denial of the new housing rebate, and did not apply for the NRRPR until the two-year deadline for doing so (under ETA s. 256.2(7)(a)) had passed – and also failed to file a Notice of Objection to the CRA assessment denying his NRRPR claim. ...

., birth and death records) whose number was determined in accordance with parameters that were subject to change by the site – and with a significant number of the credits never being applied in the periods in question. ...

" … The petitions before me are directed exclusively at the interpretation of the Income Tax Act for the sole eventual purpose of determining whether there needs to be a remission to the Receiver General of the 25 per cent tax applicable to non‑residents under s. 116(5) of the ITA. ...