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McLeod’s 2002 taxation year, and as a result, the Report notes that no consideration of possible fairness relief was necessary ...

[T]he construction that gives effect to the whole of the statute, or to the provision under consideration, should be adopted in preference to one that renders part thereof meaningless. [2] This holding contrasts with that of Lamarre-Proulx, J.T.C.C. in Craig, supra. [3] See Radage v R., 96 DTC 1615 (T.C.C.) and Noseworthy v. ...

In other words, the amendment cannot be clearly rejected here on this basis. [17]            However, if the past is any indication of the future, as I think it will be, it is clear to me—notwithstanding the defendants’ submissions—that adding patent ’748 to this debate would significantly delay the trial in this case and otherwise cause Easton to suffer irreparable damages in terms of costs. [18]            In this respect, and even if it can be held in principle, as strongly argued by the defendants, that patents ’953 and ’748 are, by and large, related and involve a similar subject, the skate boot, and that a separate action in this Court under patent ’748 is possible in principle, I am nevertheless of the opinion that we cannot rule out that adding patent ’748 in this case would give rise to the vast majority of the incidents that Easton describes in paragraph 69 of its written submissions below against the motion under consideration: (a)                 an amendment to the statement of defence and counterclaim to address infringement and invalidity of the ’748 patent; (b)                an amendment to the counterclaim to plead a breach of the implied undertaking rule and the tort of abuse of process; (c)                 the possibility of requiring further particulars by either party; (d)                motions to strike on behalf of Easton and/or Nike; (e)                 motion to sever and stay counterclaim of abuse of process; (f)                  additional documentary productions; (g)                 motion to remove Nike’s solicitors of record from the file as material witnesses and participants in obtaining the ’748 patent; (h)                 multiple sessions of oral discovery, which, to date, have taken at least twelve (12) days over six (6) years; (i)                   motions to compel answers (at least one round, most likely a few); (j)                  follow up oral discoveries; and (k)                additional expert reports. [19]            Moreover, it does not appear that the defendants have truly sought to move forward with this case since patent ’748 was issued on August 7, 2007, notwithstanding the February 2008 filing of the motion we are currently considering. ...

The other respondents are the entities involved in the actual marine transportation of the stoves. [4]                An affidavit by Stacy Walters, dated May 2, 2008, was filed by the applicants against the motion under consideration. ...

  [7]                Those who make valid voluntary disclosures for the periods under consideration are required to pay the tax and interest owing, but the Agency may waive or cancel penalties on those returns ...

This involves a consideration of real and substantial risk; a finding that the interest in issue is a public interest in confidentiality; and an obligation to restrict the remedy as much as is reasonable while preserving the interest. ·                     the salutary effects of the confidentiality order outweigh its deleterious effects ...

The proper place for considerations of this nature are in the second prong of the Borowski test – the exercise of the Court’s discretion. ...

Biller, these issues are separate from CRA considerations. CRA considered the relevant facts, and acted reasonably. ...

While this raises some sympathy, these are not relevant considerations for obtaining the status of refugee or person in need of protection. [14]            It is not disputed that the standard of review in this case is reasonableness (Warsame v. ...

The responsibility to include all of a taxpayer’s revenue earned during a year belongs to that taxpayer and it cannot be transferred on the CRA just because the latter is eventually provided with a copy of the T3 and T5 slips issued by financial institutions. [21]            Second, the Team Leader considered all representations made by the Applicant in reviewing the Second Level Request, and did not rely on irrelevant considerations. ...