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The reliability criteria is satisfied only if the contents of the document sought to be admitted into evidence are trustworthy by reason of the way the document came into existence and the circumstances allow the judge to assess its reliability …. ...

. … [G]iven that the appellant did not acquire the services, it could not provide them as in kind benefits. ...

. … ...

[C]onsistent with Nash … the first step is to identify the property to be valued [i.e., each “condo” unit]. ...

In rejecting this submission, Gleason JA stated (at paras. 15, 24): On its plain meaning, a deeming provision does not constitute an “election” or “appointment” …. ...

. … It is highly unlikely that Parliament would explicitly provide that any supply of an orthodontic appliance is zero-rated if the intention is that the supply is restricted to the wholesale level. ...

What mattered at the time … was “the relationship of the person acquiring the [house] to the builder—one of purchase and sale—[…], not the relationship between co-purchasers” (Cheema at para. 94). ...

Preston, 2023 FCA 178-- summary under Onus Summary Under Tax Topics- General Concepts- Onus assumptions of mixed fact and law were not prejudicial to the taxpayer – and an FMV assumption instead is factual The Tax Court ordered that “assumptions of fact” pleaded by the Crown in its Reply should be struck out and moved to the reasons part of the Reply on the sole ground that they were in fact conclusions of mixed fact and law. ...

In discussing the issue as to whether s. 18.5 of the Federal Courts Act precluded the judicial review application given the statutory appeal mechanism, Boivin JA adopted the finding in inter alia Best Buy (2021 FCA 161) that in such circumstances, “a complete bar to judicial review would be incompatible with the rule of law” and that both types of errors are reviewable: “errors of law are reviewable under the correctness standard via the statutory appeal mechanism in subsection 68(1) of the Customs Act, while errors of fact are reviewable under the reasonableness standard through an application for judicial review …” (para. 29). ...

In affirming this finding, Boivin JA distinguished Kevin Davis Dentistry, which gave effect to the expressed Parliamentary intent to “provide for different tax treatment of supplies of orthodontic appliances and orthodontic service” (para. 25) whereas, here, the Ontario regulations did “not amount to as clear an indicator of Parliament’s intent as the GST Act did in Kevin Davis Dentistry ” (para. 28). ...