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  [17]         With respect to the GSTC, the considerations are similar. ...

  [17]         In the case at bar, after obtaining written waivers, alerting both parties to the process and conducting the review, the Minister during or shortly after the Audit Period (now six years ago):   1)                 unilaterally preferred the representations of AFT and the facts which supported the confirmation of AFT’s assessment and the reassessment of the Appellant;   2)                 approached a consideration of a section 174 application in one form or another and decided not to proceed; and   3)                 some years later proceeded to file a Reply containing factual assumptions which are consistent with her assessing position taken from the very outset which confirmed, (without ambivalence, indecision or uncertainty as to fact and/or law) the preferred as filed return of AFT over the characterization of the payment by the Appellant ...

I do not find the bulletin of any assistance in interpreting paragraph 8(1)(c) for it sheds no light on the considerations which led the author of the bulletin to conclude that such officers are considered to be ministers. ...

The Corporation assumed the existing mortgage on the Property and paid nominal consideration to the co-investors. [12]         The evidence shows that starting around 1991 the Appellant devoted a significant portion of his time to the redevelopment of the Property. ...

However, without deciding whether it is necessary to do so, given that all parties at the hearing clearly understood that this was an appeal of the reassessment of April 18, 2016, given that pursuant to subsection 18.15(3) of the Tax Court of Canada Act appeals “shall be dealt with by the Court as informally and expeditiously as the circumstances and considerations of fairness permit” and given the inherent powers of this Court as a superior court of record to govern its own process, on my own motion, I hereby amend the appeal to be an appeal against the reassessment of April 18, 2016. [2] See the top half of the first page of the exhibit. [3] Still in the top half of the first page of the exhibit. [4] Within the family it is very unlikely one would choose to change the bill to a different member of the household temporarily. [5] Paragraph (a) of the definition of “principal residence” in section 54 of the Income Tax Act. ...

Delongchamp entitled “ Forming an Operating Limited Liability Companies Canadian and US Tax Considerations ” at the bottom of page 19). ...

She noted that the amount in issue was significant for this Court, some 2 million dollars; that it was a test case for many other similar files before the Revenue Agency; and that there were very complicated financial arrangements under consideration involving at least four major GST issues. ...

The Queen, [6] Judge Bowman’s discussion of novelty, uniqueness, complexity, difficulty and the fact that a large amount of money is involved was in the context of awarding solicitor-client costs, which are far above Tariff costs and involve considerations entirely separate from the Court’s general authority to exercise its discretion in applying the section 147 factors ...

The name on these invoices is Marc­André Lachance, Érika Lachance’s father. [43]         I will add that there are still two other important considerations. [44]         First, I note that the appellant’s testimony was not corroborated and that the only people who could have testified in her favour, Constantin Diktakis, Érika Lachance or Marc­André Lachance, were absent. ...

In consideration of the parties’ compliance with their respective obligations, the parties exchanged a full and final release from any right or recourse arising from the job, the employment relationship and its termination on October 26, 2014, including the complaints filed by the appellant with the Commission des normes du travail. [11]         The appellant testified that the payor had not counted the overtime as insurable hours for Employment Insurance purposes. ...