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Woon argues that the religious practices and beliefs of the shareholders are a relevant consideration in the context of the assumptions considered in their entirety. ...

With this work permit, she was able to find employment and submit an application to Citizenship and Immigration Canada based on the provisions relating to humanitarian considerations. ...

Phillips in Saskatchewan, legally described as NW ¼ 21-33-30W1 and NW ¼ 22-33-30 W1 (the "Land"); (d)         in 2002, the Appellant supplied the Land under a rental/lease agreement to Lowell Jacob Koehn operating as Koehn Farms; (e)         the Appellant rented/leased the Land to Koehn Farms for annual consideration of $5,440.00 plus the applicable GST; (f)          the Appellant's only commercial activity during the relevant period was the supply of the Land to Koehn Farms; (g)         at no time during the relevant period did the Appellant carry on a farming operation; (h)         the Appellant filed GST returns for the relevant period reporting tax collected/collectible, ITCs and net tax, for which the Minister paid refunds, described as follows: Period Ending tax Collectible Input tax credits claimed net tax Refunds Paid 2003-12-31 168.00 713.00-545.00 545.00 2003-09-30 240.00 710.00-470.00 470.00 2003-06-30 27.41-27.41 27.41 2003-03-31 399.00 402.35-3.35 3.35 2002-12-31 340.00 343.55-3.55 3.55 2002-09-30 301.23-301.23 303.36 *** 2002-06-30 101.73-101.73 101.73 2002-03-31 3,508.36-3,508.36 3,508.36 2001-12-31 2,507.35-2,507.35 2,507.35 2001-09-30___________3,609.96_-3,609.96_3,609.96 Total 1,147.00 12,224.94-11,077.94 11,080.07 ***includes interest of $2.13 (i)          in addition to the GST returns filed, the Appellant reported total tax collected of $2,912.00 on the sale during the relevant period of a 2001 GMC ½ ton truck and a 2001 Chrysler PT Cruiser (the "vehicles") more fully described as follows: (i)          2001 GMC ½ ton sold for $20,000.00 on which tax of $1,400.00 was collected: (ii)         2001 PT Chrysler PT Cruiser sold for $21,600.00 on which tax of $1,512.00 was collected; (j)          the vehicles were for the personal use of the Appellant and were not part of her commercial activity; (k)         the Appellant was required to report and remit the $2,912.00 collected as tax on the sale of the vehicles; (l)          in 2001, the Appellant incurred expenses to improve the Land of $1,740.00 on which tax of $121.80 was payable; (m)        in supplying the Land to Koehn Farms in 2002, except for property taxes, the Appellant was required to incur no further expenses; (n)         the Appellant sought to claim ITCs of $12,224.94 for the relevant period; (o)         the Appellant was entitled to ITCs of no more than $121.80 for the relevant period; (p)         $12,103.10 of the ITCs the Appellant sought to claim were not in respect of supplies acquired by the Appellant for use, consumption or supply in the course of the Appellant's commercial activity; (q)         the ITCs in excess of the amount allowed were in respect of amounts that (i)          could not be verified; (ii)         could not be related to the commercial activity carried on by the Appellant; (iii)        were for supplies of a personal nature such as household furniture, a television and legal fees; 17.        ...

Canada. [3] Analysis [6]      The relevant provision of the Act is as follows: 50.(1)    For the purposes of this subdivision, where             (a)         a debt owing to a taxpayer at the end of a taxation year (other than a debt owing to the taxpayer in respect of the disposition of personal-use property) is established by the taxpayer to have become a bad debt in the year, or (b)         a share (other than a share received by the taxpayer as consideration in respect of the disposition of personal-use property) of the capital stock of a corporation is owned by the taxpayer at the end of a taxation year and (i)                 the corporation has during the year become a bankrupt (within the meaning of subsection 128(3)), (ii)               the corporation is a corporation referred to in section 6 of the Winding-up and Restructuring Act that is insolvent (within the meaning of that Act) and in respect of which a winding-up order under that Act has been made in the year, or (iii)             at the end of the year, (A)        the corporation is insolvent, (B)        neither the corporation nor a corporation controlled by it carries on business, (C)        the fair market value of the share is nil, and (D)        it is reasonable to expect that the corporation will be dissolved or wound up and will not commence to carry on business and the taxpayer elects in the taxpayer's return of income for the year to have this subsection apply in respect of the debt or the share, as the case may be, the taxpayer shall be deemed to have disposed of the debt or the share, as the case may be, at the end of the year for proceeds equal to nil and to have reacquired it immediately after the end of the year at a cost equal to nil.        ...

The auditor assumed that all the income posted to the financial statements had been received by the Appellant in consideration of taxable supplies. ...

These considerations are in my view the kind of objective components referred to in the above-cited Mohammad case. ...

These considerations have lead me to conclude that, on balance, the company and the employees were not acting without separate interests, quite the opposite. ...

  [19]     Counsel for the appellant contended that I should take the settlement proposal—to reimburse the amount of the cheque—into consideration in awarding costs. ...

The Court also said that, given the complexity and detail of the Income Tax Act, in normal circumstances greater weight will be placed on a textual analysis of the provision under consideration.   ...

In Collins, it was found that the taxpayer had not ceased to be a resident of Canada because he had not "settled" someplace outside Canada. [12]     The same considerations do not apply where a taxpayer has become settled in a foreign jurisdiction. ...