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. […]   [49]            There, the Supreme Court considered the grammatical and ordinary sense of the words at issue, the scheme of the act under consideration, the legislative history and evolution of the provisions in issue and the purpose of the legislation ...

  [11] Based on his consideration of ss. 2 and 16(1) of the Regulations, he concluded that the licence itself is the property of the Crown, and not of the holder. ...

If only these sections were taken into consideration, compensation could not be effected after bankruptcy, because bankrupts would no longer be in a position to use their property to pay their debts.  ...

This may involve several considerations, including the specialized knowledge of its decision makers, whether any special procedures or non-judicial means of implementing the Act apply, and whether the tribunal plays a role in policy development.   29           In respect of the specialized knowledge of decision makers, a court can look to a tribunal’s constitutive statute and whether appointees are required to have expert qualifications, or are to be appointed by persons holding such qualifications: see Southam, supra, at para. 51.  ...

Rather, reasons for judgment tend to be framed in terms of the facts of the particular case: analysis often does not proceed much beyond the proposition that whether the "due diligence" defence has been established is to be determined by a consideration of all the circumstances of the case. [23]      In the absence of a developed analytical framework, cases are readily distinguishable on their facts, even when those facts, including the facts in the instant appeal, conform to a recurring general pattern. ...

The standard to be applied is one of reasonable consideration.  But it is clear that the proper approach to applying paragraph 55(1)(c) of the Act requires that one views the transactions as a whole rather than in isolation.  ...

In other words, in today’s language, where the Federal Court has jurisdiction under the ITO-Int’l Terminal Operators test, the Federal Court can decide a constitutional question. [50]            In light of these considerations, what should now be made of the passage in Northern Telecom? ...

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. ...