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Frequently, but not always, one excludes the other. [14]          With respect to reasonable allowances reimbursed on a non-taxable basis, subsection 6(1)(b)(vii.1) of the Act provides as follows: Amounts to be included as income from office or employment 6 (1) There shall be included in … the income of a taxpayer … Personal or living expenses (b) all amounts received by the taxpayer in the year as an allowance for personal or living expenses or as an allowance for any other purpose, except … (vii.1) reasonable allowances for the use of a motor vehicle received by an employee (other than an employee employed in connection with the selling of property or the negotiating of contracts for the employer) from the employer for travelling in the performance of the duties of the office or employment, … [15]          Similarly, paragraph 8(1)(h.1) provides for deductions from employment income as follows: 8(1) Deductions allowed Motor vehicle travel expenses (h.1) where the taxpayer, in the year, (i) was ordinarily required to carry on the duties of the office or employment away from the employer’s place of business or in different places, and (ii) was required under the contract of employment to pay motor vehicle expenses incurred in the performance of the duties of the office or employment, amounts expended by the taxpayer in the year in respect of motor vehicle expenses incurred for travelling in the course of the office or employment, except where the taxpayer (iii) received an allowance for motor vehicle expenses that was, because of paragraph 6(1)(b), not included in computing the taxpayer’s income for the year, or (iv) claims a deduction for the year under paragraph 8(1)(f); b)     Analysis of the facts [16]           On the basis of the facts, Ms. ...

(h) personal or living expenses of the taxpayer, other than travel expenses incurred by the taxpayer while away from home in the course of carrying on the taxpayer's business; 163(2) False s tatements or omissions Every person who, knowingly, or under circumstances amounting to gross negligence, has made or has participated in, assented to or acquiesced in the making of, a false statement or omission in a return, form, certificate, statement or answer (in this section referred to as a “return”) filed or made in respect of a taxation year for the purposes of this Act, is liable to a penalty of the greater of $100 and 50% of the total of  ... 248(1) “ Personal or living expenses ” includes (a)      the expenses of properties maintained by any person for the use or benefit of the taxpayer or any person connected with the taxpayer by blood relationship, marriage or common-law partnership or adoption, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit,... ...

There are two possible paragraphs that may be applicable: paragraphs 8(1)(f) and 8(1)(i) which read as follows: (f)         where the taxpayer was employed in the year in connection with the selling of property or negotiating of contracts for the taxpayer’s employer, and (i)         under the contract of employment was required to pay the taxpayer’s own expenses, (ii)        was ordinarily required to carry on the duties of the employment away from the employer’s place of business, (iii)       was remunerated in whole or part by commissions or other similar amounts fixed by reference to the volume of the sales made or the contracts negotiated, and (iv)       was not in receipt of an allowance for travel expenses in respect of the taxation year that was, by virtue of subparagraph 6(1)(b)(v), not included in computing the taxpayer’s income, amounts expended by the taxpayer in the year for the purpose of earning the income from the employment (not exceeding the commissions or other similar amounts referred to in subparagraph 8(1)(f)(iii) and received by the taxpayer in the year) to the extent that those amounts were not (v)        outlays, losses or replacements of capital or payments on account of capital, except as described in paragraph 8(1)(j), (vi)       outlays or expenses that would, by virtue of paragraph 18(1)(l), not be deductible in computing the taxpayer’s income for the year if the employment were a business carried on by the taxpayer, or (vii)      amounts the payment of which reduced the amount that would otherwise be included in computing the taxpayer’s income for the year because of paragraph 6(1)(e); … (i)                   an amount paid by the taxpayer in the year, or on behalf of the taxpayer in the year if the amount paid on behalf of the taxpayer is required to be included in the taxpayer’s income for the year, as … ii.                    ...

I do not find that high degree of negligence in connection with the misstatements of business income. ...

INTRODUCTION [1]   The appellant, Gerardo Omapas Duyo, appeals from the denial of his application for a GST/HST new housing rebate (the “NHR” or the “rebate”) of $25,015.70 in connection with the purchase of a property located at 170 Flowing Circle, Kanata, Ontario (the “Property”). [2]   In 2014, the appellant and his spouse sought to purchase the Property, but were initially unable to obtain mortgage financing. ...

Gard concluded that there had been no error by the CRA in preparing the reassessment, there was no additional delay by the CRA, there was no connection between the Applicant’s health condition and his ability to file his returns on time or to pay taxes on time, and that there were no exceptional circumstances to justify cancellation of the gross negligence penalties. [41]   Ms. ...

She further states that, generally, a request for relief will be granted when there is a “connection between a circumstance beyond the taxpayer’s control and the inability to file a complete and accurate return and pay any amount owing by the required due date” (Respondent’s Record, p. 37). ...

Date Amount 1996-11-28 $50,000 1997-07-29 $25,000 1997-08-27 $25,000 1998-06-15 $25,000 1998-09-01 $10,000 1998-12-11 $20,000 1999-01-26 $10,000 1999-03-12 $20,000 1999-06-21 $20,000 1999-10-28 $15,000 1999-12-16 $25,000 2000-01-14 $40,000 2000-01-18 $20,000 Total $305,000 [4]   At the stage of opposing the initial assessment of June 11, 2015, for the 2014 taxation year, the Appellant confirmed that her BIL was $305,000, not $610,000 as reported, and she requested an additional amount of $125,000 in connection with a loan that she had made to the Corporation on October 6, 2005. [5]   The Minister denied the loss claimed as a BIL because the loans made by the Appellant to the Corporation did not involve any interest or repayment terms and because the Corporation had not had any revenue-generating activities for several years. [6]   At the hearing, Counsel for the Respondent acknowledged the existence of the Appellant’s debt to the Corporation and acknowledged that it became a bad debt in 2014. [7]   Ms. ...

Whether in Business or in connection with the CBSA Work, Mr. Hara said it best, “I provided unbiased and professional translation as I saw fit”. ...

Although she claims that, along with Repaco, she developed a new mini-press for welding, in my opinion, that could not be considered either because, first of all, Repaco did everything for free, and so there is no expense claimed in connection with that. ...