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Subsection 160(1) of the Act reads:          160(1) Where a person has, on or after the 1st day of May, 1951, transferred property, either directly or indirectly, by means of a trust or by any other means whatever, to                        (a) his spouse or a person who has since become his spouse;                        (b) a person who was under 18 years of age, or                        (c) a person with whom he was not dealing at arm's length,                   the following rules apply:                        (d) the transferee and transferor are jointly and severally liable to pay a part of the transferor's tax under this Part for each taxation year equal to the amount by which the tax for the year is greater than it would have been if it were not for the operation of sections 74 to 75.1, in respect of any income from, or gain from the disposition of, the property so transferred or property substituted therefor, and                        (e) the transferee and transferor are jointly and severally liable to pay under this Act an amount equal to the lesser of                            (i) the amount, if any, by which the fair market value of the property at the time it was transferred exceeds the fair market value at that time of the consideration given for the property, and                            (ii) the aggregate of all amounts each of which is an amount that the transferor is liable to pay under this Act in or in respect of the taxation year in which the property was transferred or any preceding taxation year,                   but nothing in this subsection shall be deemed to limit the liability of the transferor under any other provision of this Act.                   ... She contends that the Tax Court judge failed to consider the value of consideration given by her on the transfer of the matrimonial home and thereby deprived her of the benefit of subparagraph 160(1)(e)(i) of the Act. ...

Taking into consideration all of the circumstances, including the testimonies, admissions, documentary evidence, submissions of Counsel and available case law, I am of the view that the Appellant has not succeeded in this onus. ... Nor are we persuaded on that particular record that the terms and conditions under which the respondent Griffith was employed and the remuneration paid were not "analogous" to a contract of service within the meaning of subsection 34(1). [7]      This leaves for consideration the argument that the two sets of regulatory provisions go beyond the statutory authority conferred by paragraph 4(1)(c) of the Unemployment Insurance Act and paragraph 7(1)(d) of the Canada Pension Plan, respectively- in other words, that they are ultra vires. ...

  [6]                This is a direct attack on sections 110.2 and 120.31 of the ITA, based on considerations that are wholly extrinsic to the ITA. ... In as much as I am empowered to do so, I suggest that the amount is in fact interest and recommend that the Appellant's application under the fairness package be given careful consideration. ...

The grounds of appeal relate to her consideration of those factors.   [11]            The appellants correctly point out that Justice Woods, in determining who effectively controlled the operation of the hotel, generally preferred the evidence of the appellant Mr. ...   [15]            The appellants submit that Justice Woods erred in her consideration of the factors of chance of profit and risk of loss. ...

The Minister assessed the Succession on the basis of the transfer from Maurice Boivin to the Succession, without consideration, at a time when Mr. ... The assessment of Vincent Boivin was established on the grounds that the transfer was made without consideration at a time when the Estate had, pursuant to section 160 of the Act, a tax debt from the transfer made by Maurice Boivin to the Succession ...

In his view, her failure to apply Worrell is the result of her taking into account irrelevant considerations and ignoring relevant considerations. ...

Trueman’s letter dated October 28, 2015, that other circumstances are taken into consideration to determine whether a taxpayer is in the same situation as SDL employees. ... In addition, an individual’s financial circumstances would also be taken into consideration as well as their overall participation in the stock purchase plan. ...

Counsel for the Appellant: Mieszko Chuchla Counsel for the Respondent: John Bodurtha   ORDER WHEREAS the Respondent has brought a motion pursuant to section 69 of the Tax Court of Canada Rules (General Procedure) in which he seeks an Order to strike the Notice of Appeal filed with the Court on May 18, 2018, and allowing the Appellant to file a Fresh Notice of Appeal in accordance with the applicable rules of procedure and allowing the Respondent to file and serve a Reply 60 days after the date of service of the Fresh Notice of Appeal; and,   WHEREAS counsel for the Appellant has opposed the motion;   UPON CONSIDERATION of the written submissions made by the parties,   IT IS ORDERED that   1) the Notice of Appeal is struck,   2) the Appellant may file and serve a new Fresh Notice of Appeal that complies with the Rules no later than the 20 th day of November 2018,   3) the Respondent shall file and serve a Reply to Notice of Appeal no later than 60 days after service upon it of the Fresh Notice of Appeal, and 4) there will be no order as to costs. ... Although the document is headed “Affidavit in Opposition to Motion” it is clearly written representations and not an affidavit. [6]   Nothing in the submissions directly requests a hearing of the motion and nothing in the submissions gives reasons why the matter cannot be dealt with in writing although the reference at the bottom of the second page to documents or other evidence that may be used at the hearing of the motion implies that counsel for the Appellant expects there to be a hearing. [7]   Assuming that counsel for the Appellant intended to request a hearing, I would note that rule 69 reads as follows: 69(1) A party filing a notice of motion may, at the same time, or subsequently, file a written request that the motion be disposed of upon consideration of written representations and without appearance by the parties. (2) A copy of the request and of the written representations shall be served on all parties served with the notice of motion. (3) A party served with a request shall within twenty days, (a) file and serve written representations in opposition to the motion, or (b) file and serve a written request for a hearing. (4) When all parties served with the request have replied to it or the time for doing so has expired, the Court may, (a) grant judgment without a hearing, (b) direct a hearing, or (c) direct that written representations be filed. [8]   It is clear that once the step in paragraph (3) of the Rule has been completed the Court may exercise the powers contained in paragraph (4). ...

Quiku also has an older child from a previous relationship. [4]   This review involves consideration of the marital history of Ms. ... Peprah is not a member of the family class is reasonable. [8]   The standard of review for a decision by the IAD determining an appeal of an application for spousal sponsorship under the IRPA is presumptively reasonableness, because it involves consideration of the home statute of the IAD and questions of mixed fact and law: Alberta (Information and Privacy Commissioner) v Alberta Teachers' Association, 2011 SCC 61 at para 30; Dunsmuir v New Brunswick, 2008 SCC 9 at para 54 [Dunsmuir]. [9]   In this case, the IAD was required to make a determination on the validity of a marriage made in Ghana, under foreign law. ...

Bokhari responded to the fairness letter in October 2017, and submitted for consideration a new job offer as a retail sales supervisor (a gas station shift supervisor). ... Bokhari provided no clear explanation as to how he was able to submit a new job for the Officer to consider, despite the fact that it was not related to the job in the Certificate of Nomination, or on what basis the Officer’s consideration of the new job related to the intent of the SINP.   ...