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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.   ...

However, there is nothing in the VDP Circular, nor in the statutory context within which it operates, to support the argument that the appellant had a legitimate expectation that the reassessment process would be suspended pending final consideration of the VDP application. [18]   Finally, insofar as the appellant’s assertion of harm arising from the Minister’s resort to enforcement powers is concerned, with the exception of jeopardy orders, subsection 225.1(1) precludes enforcement action once a taxpayer has filed a notice of objection, and subsection (3) prevents the Minister from taking collection action once an appeal has been filed with the Tax Court. Any defence to potential criminal proceedings arising from his disclosure is for the sole consideration and determination of the criminal courts. [19]   Before concluding, one element of the Federal Court decision requires comment. ...

Motion dealt with by way of written submissions By: The Honourable Justice Susan Wong Parties: Agent for the Appellant: Motlagh Shirazi Counsel for the Respondent: Cherylyn Dickson   ORDER   Upon motion by the Appellant seeking leave to have its sole director and officer Motlagh Shirazi represent the Appellant in this appeal;   And upon consideration of the Appellant’s notice of motion, affidavit and supporting materials and the written submissions of the Respondent; IT IS ORDERED THAT: The motion is dismissed on the following basis: a) the time for the Respondent to file and serve her written representations in respect of this motion is abridged to February 4, 2020; b) the Appellant shall retain counsel to represent it in this appeal; c) a Notice of Appointment with respect to new counsel shall be filed by the close of business three months from the date of issuance of this order; d) the parties’ October 10, 2019 joint request to amend the timetable order shall be held in abeyance until new counsel is appointed; and e) costs will be in the cause. ... Based on common law factors [19]   If my above analysis is incorrect, then I would also conclude that the Appellant must be represented by counsel based on my consideration of the non‑exhaustive list of factors for applying subsection 30(2) of the Rules, as set out in WJZ Enterprises v. ...

The Queen, 2019 TCC 20. [8]   After careful consideration, I repudiate the conclusion, expressed in my own previous decisions, that a corporation cannot appear in person. ... This leads to careful reflection of considerations like those included in WJZ Enterprises v. ...