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He did neither. [13]            Graham J. demonstrated a careful consideration of the evidence in his reasons for exercising discretion to allow the Crown’s motion. ...

Les facteurs pris en considération étaient que l’erreur n’était pas intentionnelle, qu’elle a été faite de bonne foi et qu’elle ne constituait pas une tentative délibérée d’induire en erreur ou de retarder l’instance. ...

When the funds were distributed, amounts were withheld for United States income taxes. [4]   The issue is whether the payment from the IRA should be included in his 2012 income. [5]   The Canada Revenue Agency added the amount to the Appellant’s income; the Agency also took account of the United States taxes withheld and allowed a foreign tax credit. [6]   The Appellant’s position is that the amount received from the IRA should not be subject to tax because it is an inheritance. [7]   While the Appellant received the funds as a result of his father’s death and while generally the receipt of an amount distributed from an estate does not in itself trigger tax, there are two important considerations here. [8]   First, the Appellant received the amount as a distribution from an IRA and not from his father’s estate. ...

A consideration of factors (iii) and (iv) convince me that these corporations should be represented by a lawyer in these appeals. ...

It must be noted that the appellants' correspondence challenging the bill of costs dated April 3 and July 7, 2009, enclosed with the general correspondence attached to the respondent's documents, was taken into consideration during the taxation ...

Consideration of such applications is entirely within the discretion of the Minister. [10]   In the specific circumstances of this case I would hope that the Minister would not deny any subsection 152(4.2) application brought by Ms. ...

In light of the nature of the Minister’s discretion under subsection 220(3.1) (Telfer, at para. 40) and the delegate’s consideration of multiple factors, the Federal Court did not err in finding the decision reasonable. [9]   We will therefore dismiss the appeal with costs set at an amount of $2,500.00 (all inclusive). ...

Based on its consideration of all of the evidence, the Tax Court found, on a balance of probabilities, that the Minister sent the notices of reassessment to Ms. ...

Further, she argues that the CRA did not take CIBC’s error into consideration. [11]   In response, the Respondent argues that there is no obligation on the CRA to demonstrate that a taxpayer has received mail; it only needs to demonstrate that such mail was sent. ...

Canada (Citizenship and Immigration), docket IMM-2610-19 Date: 20190815 Docket: IMM-2610-19 Toronto, Ontario, August 15, 2019 PRESENT:   Madam Justice McDonald BETWEEN: OSCAR DANIEL RODRIGUEZ RAMIREZ DANIEL FELIPE RODRIGUEZ SUAREZ CLAUDIA LILIANA SUAREZ CHANCI Applicants and THE MINISTER OF CITIZENSHIP AND IMMIGRATION Respondent ORDER UPON MOTION on behalf of the Applicants for an order staying their removal to Colombia, scheduled for August 16, 2019, pending the determination of their request for an extension of time to file an application for leave and for judicial review of the decision of the Refugee Protection Division (RPD) dated February 1, 2019 finding that their claims had been abandoned; AND UPON considering the Affidavits and written submissions filed on behalf of the parties; AND UPON hearing oral submissions on behalf of the parties on August 15, 2019, at a special sitting of the Court; AND UPON noting that the granting of an extension of time for filing the underlying application for leave for judicial review is a condition precedent to the consideration of the Applicants’ Motion for a Stay of their Removal;   AND UPON noting that the applicable test for the granting of an extension of time is set out in Canada (Attorney General) v. ...