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Therefore, there would have been no advantage in preparing for a tournament by studying the previous games of potential opponents. … [242] … Mr. Duhamel was playing in poker tournaments and not in private games where he could have stopped playing as soon as he lost or won a large sum of money. … [243] … Mr. Duhamel partied very often and sometimes arrived at the various tournaments in a "morning after" state. … [244] … Mr. ...

. … The reasons and the judgment both deal with the rebate issue. Clearly the rebate issue has not been overlooked and has been adjudicated. … There is no question here of facts arising after the hearing. Furthermore, Jorré DJ found that even if that were not the case, there were two additional reasons that would have led to the same conclusion, stating (at paras 29, 34, 36, 47): What matters … is not what was intended but what was done. … I … asked “So you’re conceding the 27746 GST rebate?” ... Given that the rebate issue was conceded, we are clearly not in a situation where this Court should vary the outcome even if it could. … [B]efore any variation could be considered and even it could otherwise be varied, fairness would require the matter be reopened to explore what the $1,866 [in employment expenses claimed on line 212 and allowed by the Minister] was and whether the Appellant paid any GST or HST on the amount. ...

Alan & Company Limited v El Nasr Export & Import Company, [1972] 2 QB 189, [1972] 2 All ER 127 … held that no consideration needed to be moving from the party which benefits from the waiver. … …If I am in error … that [no] consideration is required, I am of the view that there is good and valid consideration flowing to the Appellant. The Appellant received the benefit of not having to spend any time or effort or cost because her appeal did not proceed … [and] the Respondent held the Appellant’s objections in abeyance, and ensured the Appellant’s assessments would be confirmed in accordance with the lead case. ... Respecting “undue pressure,” he stated (at para 26): The case law … appears to point quite strongly that where CRA says to the Appellant either sign the waiver or we will close the file that is not undue pressure (McGonagle v The Queen, 2009 TCC 168.... ...

Bocock J stated (at paras. 15, and 16): The two-step test for determining expert evidence admissibility was … clarified in White Burgess [2015 SCC 23, at para. 23] and may be summarized below: 1. ... Gatekeeper function / Residual discretion to exclude: This step is a cost-benefit analysis of the help and harm of the evidence. ... Sadoway’s report … comprised a legislative history and context concerning various federal statutes; and … represented observation evidence on wait times, durations and pathways for refugee determination. … … An expert opinion should be information that is outside the experience or knowledge of the judge. … [A]n expert witness’ legal opinion will not usually be necessary and should be excluded at the threshold step …. … The overall necessity and probative value of the topic as evidence from a lawyer is low relative to the time and cost of having an additional expert testify on topics already covered in the context of social science [reports] …. ...

In rejecting the taxpayers’ request that the Tax Court cancel the accumulated interest on their assessments, MacPhee J stated (at para. 24): The case law is clear: if a taxpayer wants a review of the Minister’s decision concerning interest relief he must file an application for judicial review at the Federal Court under section 18.1 of the Federal Courts Act …. ...

Sommerfeldt J concluded (at paras. 167, 169): While the “assumption underlying the test in Stewart is that a commercial activity is undertaken for profit,” [Stackhouse, at para. 103] … the documentary evidence calls that assumption into question …. The documentary evidence … does not give any indication that Mr. Chad or Mr. ... Thus … the intention of Mr. Chad and Mr. Hodgins, in implementing the Trades, was not to earn a profit …. ...

In allowing the taxpayers’ appeals of the denial of such SBD claims through the application of s. 256(2.1), MacPhee J stated (at para. 66): I also am satisfied that the main reasons for the second tier of corporations which were created as part of the restructuring were to: · obtain tax deferrals of up to 25 months; · be more flexible in moving partners in and out of the structure ….; · be able to deal with their concerns about Mr. ...

In finding that the oil-processing equipment included in TMT 4 and 5 also so qualified, he stated (at paras. 82-83): … [T]he oil processing equipment in TMT 4 was also constructed to be used by Stark at its premises …primarily for the purpose of processing Stark’s oil for sale. … Bruce Power’s nuclear power facility … contract with Areva … [was a] situation... similar to that of the seismic equipment in Capilano International, in that Stark expected to bring TMT 4 back to its premises at Bailey’s Brook and continue primarily to process its own oil for sale, which it did. … [G]iven that the contract between Stark and Areva was only for 10 months, and given that the expected working life of TMT 5 would undoubtedly have been far greater than that, I find that the oil processing equipment in TMT 5 also comes within the principle established by Capilano International. ...

Only the relieving provisions in Article 10 of the Luxembourg Treaty … and Article X of the Barbados Treaty … addressing dividends … raise the issue of beneficial ownership. ...

In rejecting this submission, MacPhee J stated (at para. 19): An implied contract … does not meet the requirements of the Act in order to make a deduction of support payments. ... The parties continued through the 2018 taxation year to consider themselves bound by their 2011 separation agreement. … … I am guided by the plain meaning of the words of the Act …. ...