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Counsel for the appellant stated in writing that the game records from the Full Tilt Poker website were not available and that he and his client would not take steps to obtain the above‑mentioned records from the other gambling websites. [74] The appellant’s unreported business income was determined using the net‑worth method following an audit of the appellant’s personal bank records; his credit card statements; the Equifax report; the land register in relation to the residence that the appellant had acquired, which was located at 3637 Robert‑Lepage Street in Quebec City; the appellant’s file at the Société d’assurance automobile du Québec; various interviews given by the appellant; and other information about the appellant that was available on the Internet. [75] The appellant’s net worth was compiled following consideration of a document entitled “ Sommaire de l’actif et du passif à partir de février 2012 ” ([translation] “summary of assets and liabilities from February 2012”), which the appellant’s counsel submitted at the initial interview with the appellant. ...

Since the 2 012 allowance i s not exc l uded from 2013 inc o me by virtue o f subparagraph 6(1)(b)(v), the n subparagra p h 8(1)(f)(iv) whic h precludes deductions only where subpa r agraph 6(1)(b)(v), is engaged, does not g et triggered either. [51] This type of probl e m invites a consideration of the purpose o f sections 5, 6, and 8 o f the A ct. ...

Specifically subsection 18.15(3) provides that: (3) Notwithstanding the provisions of the Act under which the appeal arises, the Court is not bound by any legal or technical rules of evidence in conducting a hearing and the appeal shall be dealt with by the Court as informally and expeditiously as the circumstances and considerations of fairness permit. and b) I am mindful that the CRA took eight years to process the appellant’s notice of objection. ...

That scenario is too remote to merit consideration because: No argument was presented as to how, as a matter of law, such a scenario could arise in this case; and There was no evidence that Petro Uno was in financial difficulty. [74] In his evidence, Mr. ...

The taxpayer decided to pay the disputed tax based on the consideration that if “the reassessments were ultimately found to be incorrect, [it] would be entitled to a refund of the tax with interest”, while not paying could result in being “obliged to pay the full amount of the assessed tax, plus non-deductible interest” if the reassessments were found to be correct. [94] Munich Re [95] involved a non-resident corporation that conducted an insurance business in Canada and elsewhere. ...

In the matters under consideration, Mr. Brown found that neither Mr. Hennessey nor Eastern Health “can be considered the deemed employer” (Exhibit P-5).    ... I would say that no consideration would have been given because Mr. Hennessey would have been well aware through his conversations with collections that the idea – one of the reasons an individual account was set up in January 2006 was to facilitate him keeping current with current remittances.  ...

C.A.) is, in my view, the leading pre- Descôteaux judicial consideration of the relationship between solicitor-client privilege and search warrants under the Criminal Code  .  ... Considerations of fairness in the process remain determinative (Novak v. ...

Consideration of this context will enable a reviewing court to assess and understand the nature of the individual parts of the series when analysing whether abusive tax avoidance has occurred. ... Of course, in the GAAR analysis, the entire series of transactions must ultimately be taken into consideration to determine whether the tax benefit results from an abuse of the provisions relied upon ...

Bryant, The Law of Evidence in Canada, Second Edition, Butterworths, Toronto and Vancouver, 1999, at paragraph 14.96, page 756, other considerations unique to the adversarial system, such as fairness to the opposite party and consistency of positions, may come into play. But the Court cannot find any such considerations here. [103]        Normally, the essentials of a waiver of a legal right (such as a time limitation or contractual rights) include a conscious intention to relinquish that right (see Saskatchewan River Bungalows Ltd. v. ...

Peter Sommerer grants the Sommerer Privatstiftung the right to transfer the voting, dividend, and subscription rights against payment of a consideration of CAD 0.66 per share.   ... The property sold to the trust cannot, as argued by the Respondent, be viewed as "original property"; it can only be substituted property, as consideration was given for it by the trust.   ...