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Badr Bourabaa, is the initial shareholder, one of the Corporation’s directors, and its President since it was incorporated; d)   All supplies made by the Corporation during the period in dispute were taxable supplies for which GST on the value of the consideration of the supply was payable to the Corporation, which was to be collected and remitted to the Minister; e)   The Corporation failed to remit to the Minister the GST collected for the period of December 1, 2013 to May 31, 2014, and it did not file a tax return for the period of September 1, 2014 to November 30, 2014; f)   At the end of the audit conducted by the Minister, whose observations will be set out in greater detail below, the Minister concluded that, for the reporting periods, the Corporation failed to remit to him a total of $12,414.61 as net GST collected or to be collected, but not remitted; g)   On July 29, 2015, a certificate of non-payment was issued against the Corporation; h)   Since all attempts to collect the money owed by the Corporation were unsuccessful, a writ of seizure and sale was issued on October 9, 2015, and was returned unfilled on November 12, 2015; i)   The Appellant was one of the Corporation’s directors during the period of March 31, 2014 to December 31, 2014; j)   On February 2, 2016, the Minister issued the notice of assessment bearing number F‑061467 in respect of the Appellant, as a director of the Corporation, in order to claim from him the net GST amounts owed by the Corporation, all in accordance with subsection 323 (1) of the ETA; k)   The Appellant, as President, director and shareholder of the Corporation, did not act with the degree of care, diligence and skill that a reasonably prudent person would have exercised in comparable circumstances to prevent the Corporation from failing to meet its obligations under the ETA; l)   As a result, the Minister assessed the Appellant, as director of the Corporation, for a total amount of $12,414.61; [4]   Mr. ...

Justice Webb also noted that the overriding consideration in deciding whether an extension of time should be granted “is that the interest of justice be served”. [35]   Justice Webb also stated in Akanda Innovation Inc. v HMQ [12], that an applicant need not satisfy all the factors listed in the decision of Grewal to obtain an extension of time. ...

Employment Insurance Regulations 6 Employment in any of the following employments, unless it is excluded from insurable employment by any provision of these Regulations, is included in insurable employment: (e) employment of a person as a driver of a taxi, commercial bus, school bus or any other vehicle that is used by a business or public authority for carrying passengers, where the person is not the owner of more than 50 per cent of the vehicle or the owner or operator of the business or the operator of the public authority Insurable Earnings and Collection of Premiums Regulations Passenger Vehicle Operators 9 (1) Every owner or operator of a business or public authority that employs a person or persons in employment described in paragraph 6(e) of the Employment Insurance Regulations shall, for the purposes of maintaining records, calculating insurable earnings and paying the premiums payable on those insurable earnings under the Act and these Regulations, be deemed to be the employer of every such person whose employment under that paragraph. b) The authorities [19]   The application of the two stage inquiry provided for in Connor Homes, which itself directs the consideration of the Wiebe Door [2] factors needed to answer the central question in Sagaz [3], is the course this Court shall follow. ...

After consideration of the relevant facts and circumstances, a delegated official of the CRA (see¶ 17) will decide whether it is appropriate to: … (a) waive or cancel penalties and interest under subsection 220(3.1);... ¶ 23. ...

The dance lessons had monetary value and were consideration paid for services rendered, so the Appellant was remunerated. [57]   While the Payer’s periodic cash-flow problems were outside of the Appellant’s control, she made decisions about the amount of her remuneration on a monthly basis, as shown by the downward and upward fluctuations over the course of the Period. ...

The amounts noted in the slips are based on personal expenses the Appellant allegedly incurred during the relevant year. [23]   On June 24, 2013, DeMara filed, on behalf of the Appellant, the Appellant’s 2011 income tax return showing total income of $56,149.03 comprised of the following:- employment income of $144,853.82- other income of $182.37- a loss from farming of $26,181.45- a business loss of $62,705.71- a capital loss of $62,206 [24]   The statement of business or professional activities filed with his 2011 income tax return states that he carried on a consulting business that realized no revenue and incurred interest expenses of $62,205.71 and legal, accounting and other professional fees of $500. [25]   The Appellant testified that he never carried on a consulting business and did not incur the loss of $62,205.71. [26]   Attached to his 2011 income tax return is Schedule 3, which shows that he disposed of bonds, debentures, promissory notes and other similar properties with an adjusted cost base of $62,206.00 for a nil consideration. ...

Thus I would not disturb the Respondent’s auditor’s position as to contributions from these two individuals. [26]   Regarding the Canadian Tire MasterCard credit card, I concur with Respondent’s counsel that in the absence of beginning and end of year balances, nothing really can or should be done to include consideration of this credit card in the calculation of net worth. [27]   I also agree with Respondent’s counsel that if Appellant’s counsel wished to cross-examine the CRA auditor on aspects of the audit, they should have taken pre-hearing steps to obtain the auditor’s notes and working papers themselves, to do so. ...

If a person has more than one place of residence, the following are some of the factors that are taken into consideration when determining if the residence qualifies as the primary one: whether the individual intends to use the home as his or her primary place of residence, the length of time the individual inhabits the premises, and the designation of that address on personal records. ...

That success was no better or worse than what the party could have hoped to achieve and thus neither argues for higher nor lower costs. [12]   To this I would add that the merit of the Respondent’s case is not relevant to the Court’s consideration of the result. ...

Good judgment must be exercised and all relevant factors of a case should be taken into consideration (Guidelines at p 9). [24]   Here, Internorth applied for remission on the basis of incorrect action or advice on the part of the CRA officials.   ...