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ISSUES [13]         The three issues for consideration in these Appeals are: a)      whether the Subject Deposits, as summarized in Table 4, were derived from loan repayments or other non-taxable sources or were derived from unreported income; b)     whether the Minister properly reassessed Mr. ...

Given that at the hearing the taxpayer’s number was never disputed and given that subsection 18.15(3) of the Tax Court of Canada Act says “[n]otwithstanding 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”, I am simply going to assume that $29,225.45 is correct. ...

The assessment was made on April 30, 2013, and the appellant filed his notice of objection on July 18, 2013. [69]   The CRA informed the appellant of the basis for the assessment well before the hearing of the motion before the Court and the appellant had the opportunity to adjust or amend his motion to take the assessment into consideration. ...

The receipt indicates the following: [translation] “batch of jewellery valued at $25,000.00 in payment (consideration) for land located in Saint-Didace in Maskinongé”. [77]          Mr. ...

However, even if such an issue were not now moot, the following considerations would lead the Court away from such a factual finding in the circumstances of this appeal: a) on balance, it is just as likely that the entity in control and possession of EMI Macao’s property was EMI Corp pursuant to its legal agreement to provide administrative services and import the goods acquired by EMI Macao. ...

However, paragraph 241(3)(b) clearly allows for the production of evidence in “any legal proceedings relating to the administration or enforcement of” the Act. [27] Accordingly, while the privacy of tax information is, of course, an important consideration, section 241 has no direct application here. [28] The general rule is that, where a document is relevant, it will have to be produced in its entirety. ...

Poisson did not simply take the auditor’s work at face value but rather conducted a serious review of it and gave real consideration to potential problems that could have arisen as a result of the different methodologies the auditor employed. ...

For income tax purposes, the jurisprudence has established that “a gift is a voluntary transfer of property owned by a donor to a donee, in return for which no benefit or consideration flows to the donor.” [21] Tax advantages received from a gift, however, is not normally considered a “benefit” that would vitiate the gift because doing so means charitable donations deductions would be unavailable to donors. [44]   Accordingly, there must be: (1) a voluntary transfer of property by the donor; (2) the donor owned the property immediately prior to the transfer; and (3) the donor did not receive a non-tax benefit from the donation. [45]   Subsequently, the Federal Court of Appeal clarified the third requirement in Friedberg, that anticipation of or expectation of a material benefit by the donor is sufficient to vitiate an otherwise valid gift. [22] The third no-benefit requirement is also expressed as whether the donor had donative intent at the time the donor made the gift. [23] Accordingly, the issue in this appeal is whether the appellant had the donative intent when he paid the Amount to Global. ...

Moreover, because the present case involves both the CPP and the EI Act, I think it would provide the Federal Court of Appeal with the opportunity to compare the applicable principles, considerations and tests under each of those Acts and, ultimately, provide future guidance for lower courts.   ...

Rather, he intends to make the patents available to others, presumably in consideration of a royalty or some other form of compensation. ...