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This defect has to do with the role that notaries and lawyers are expected to play in safeguarding their clients’ right to professional secrecy and the fact that they ultimately bear alone the burden of safeguarding that right when a requirement is issued. [54]                           Judicial consideration of a requirement under s. 231.7   of the ITA   is not automatic. ...

That case dealt with an assessment made under section 160 of the Income Tax Act, which renders a non-arm's length recipient of a gratuitous transfer of property from a delinquent taxpayer liable, jointly and severally with the transferor, for the transferor's tax liability, up to a limit defined as the lesser of the extent to which the value of the property transferred exceeds the value of any consideration that may have been given for it, and the total of all amounts each of which is an amount that the transferor is liable to pay under this Act in or in respect of the taxation year in which the property was transferred or any preceding taxation year. [11] It was the latter expression that applied in that case. ...

Adjustments to the 2001 taxation year of $244,525.04 net of increases to the Appellant’s net worth in the year 2000 of $29,352.70, effectively reduce the Appellant’s assessed income by $215,172.34, to approximately $5,423 before taking into consideration the conceded adjustments for china gifts of $2,269 and other minor personal expenditures that were the subject of disagreement between the parties. ...

A   Well, the – the tax shelter position was developed starting at this time and forward for – for – as a consideration for all the arrangements, including the Union CAL trading joint venture.   197. ...

With respect to financial risk, I respectfully agree with my colleagues that the appellant in consideration for a higher pay gave up many of the benefits which usually accrue to an employee including job security. ...

I would like to point out a few things for your consideration:  -          Revenue Canada, Taxation would, in my opinion, not accept many of the components of the statement of income and expenses, should they ever do an audit. ...

  [44] Since counsel for the Respondent emphasized Duguay, counsel for the Appellants submitted that the judge in Duguay was motivated by tax fairness considerations because the CSN union paid Mr.  ...

  [86]     The position of counsel for the Appellants is that in assessing the cases, the Minister failed to take into consideration the part-time work a person is entitled to do while receiving employment insurance benefits. ...

I shall deal with it after consideration of the second preliminary objection. [59]     In Smith Kline Beecham Animal Health Inc. v. ...

The various representations received and all relevant elements will be taken into full consideration. ...