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In this connection, consideration must be given to certain sections of the Act, in addition to those already cited. ...

This is an important section for consideration since it was under it that the Chief Dominion Customs appraiser purported to make his appraisal. ...

The problem in the case at bar is not the same as that under consideration in L f Institut de Notre Dame des Missions v. ...

The character or nature of the transaction must be viewed in the light of the circumstances under which it was embarked and the decision as to the side of the line on which it falls made after careful consideration of its surrounding facts. ...

On January 31, 1944, by deed and bill of sale, the realty and all other assets of the old company were conveyed to the new company, the consideration therefor being 800 redeemable preference and fully paid up shares and 3000 shares without nominal or par value of the new company, to be allotted to the old company or its nominees. ...

Nor is it reasonable to exclude from consideration all errors flowing from a mistake about the quantum of available contribution room or all errors caused by bad advice received from a third party. ...

There is also an expectation that individuals will immediately correct and manage their TFSA accounts within their contribution room limit after being informed by a notice of assessment. [48] Lastly, the Applicant submits that the Second Reviewer did not take into consideration the following facts contextually and holistically: the Applicant’s tax filing history as primarily being in a refund position each year; the Applicant took corrective action immediately after checking her 2020 NOA; and the CRA’s delay in notifying the Applicant. ...

She further noted that [translation] “ when determining whether to exercise discretion under subsection 125.7(16) of the ITA, the Minister may take into account the [Frequently Asked Questions] as well as the Taxpayer relief provisions, administrative law and any relevant considerations, on a case-by-case basis.” ...

In general, under this section, if an individual transfers property to their spouse or common-law partner for consideration that is less than the fair market value of the property transferred, the Minister of National Revenue can assess the transferee for all or a portion of the unpaid tax debt of the transferor. [2] The Tax Court Judge adopted the decision of Graham J. in Kuchta v. ...

Elements of the legal and factual contexts of a decision operate as constraints on the decision maker in the exercise of its delegated powers. [106] It is unnecessary to catalogue all of the legal or factual considerations that could constrain an administrative decision maker in a particular case. ...