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Three key considerations when evaluating the need to request information are audit scope, relevancy and reasonableness, and transparency. [22] The Minister responds that the CRA is not limited to auditing only the taxation years within a taxpayer’s normal reassessment period. ...

There must have been tactical or strategic considerations at play. Counsel for the Applicants on judicial review suggested that an inadvertent or honest mistake may suffice; there is no need to find that counsel was incompetent to argue violation of natural justice. ...

Pastuch’s requests for accommodation as a request under section 69 of the Tax Court of Canada Rules (General Procedure) to have this motion determined upon consideration of written submissions. ...

In my view, the considerations identified in Kandiah and Goulet, supra, also apply to the issue of occupancy of the premises after substantial completion of construction. ...

Analysis: [52] As stated, the question for the Court’s consideration is whether the appellant UCI has established on a balance of probabilities that monies totalling $265,000 deposited into Mr. ...

The CRA simply declined to do so. [69] I am mindful of the fact that the CRA may face difficulty in collecting the HST that was payable on the consideration paid by the Appellant in respect of the Concurrent Leases at issue herein. ...

As provided in subsection 41(2) of the Regulations, a “prescribed person” is an individual who would be entitled to claim a rebate under subsection 254(2) of the ETA (if the total consideration was less than $450,000). ...

It was also agreed at the time of the sale that the Appellant would provide services as a chartered accountant and as a consultant to Roe McNeill & Co. and to its clients for a period of three years in consideration of a guaranteed minimum fee of $225,000 over the three year term. 5. ...

The fact that at New Park Apartments television cable service and a pool were also made available to the tenants as part of the consideration for their rent does not alter in any way the character of the income of New Park Apartments Limited: such facilities are very common in a certain class of modern apartment building and should be viewed as no more of a “service” than the provision of secure locks on the doors or electrical outlets in the walls.... ...

This question was not under consideration before the Federal Court of Appeal in Cival. ...