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I am of the view that an exact register of the hours worked must be provided in order to make an SR&ED claim (Hypercube …). ...

. … ...

. … I do not require specific details to appreciate what a difficult time this would have been for Ms. ...

White … continued to have full access to the funds in the account. Accordingly, he vacated the s. 160 assessment, and found that the s. 325 assessment could only be made in the smaller amount ($34K) of the transfers that had, in turn, been made from their joint account to the taxpayer’s own bank account. ...

. … [T]he Appellants are [still] the children of …[the father]. ...

Campbell J stated that these constituted “exceptional circumstances and facts” (para. 18) which allowed her to conclude that the taxpayer could avail herself of the due diligence defence – so that the appeal was allowed. ...

That assumption is consistent with the drafting structure in the concluding portion of paragraph (f) of the definition of “builder” [in s. 123(1)]. ­­­­­­­­­­­­­­ ...

The Queen, 2020 TCC 128-- summary under Adjusted Cost Base Summary Under Tax Topics- Income Tax Act- Section 54- Adjusted Cost Base value of shares included in fee income established their ACB St-Hilaire J found that the value of shares that a broker (Lockwood) received for its services was to be included in its income when its entitlement to receive those shares was established – which occurred when it reached a settlement agreement in its 2012 taxation year that established the number of shares that it was entitled to receive from a successor (AOI) to the original client. ...

The Queen, 2021 TCC 13-- summary under Subsection 49(1) Summary Under Tax Topics- Other Legislation/Constitution- Federal- Tax Court of Canada Rules (General Procedure)- Section 49- Subsection 49(1) “taking note” of a fact pleaded by the taxpayer is not a permitted Crown response Graham J concluded his reasons by stating: Paragraphs 49(1)(a) to (c) … require that a reply to a notice of appeal state the facts in the notice of appeal that are admitted, the facts that are denied and the facts of which the respondent has no knowledge and puts in issue. ...

. … Accordingly, where an admission is contradicted by the evidence, the admission should be regarded as having been made in error. ...