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In his view, paragraph 57 of Malenfant, on which London Life based its argument, cannot be read as propounding a rule in this regard. [19]            Second, the judge considered whether subparagraph 449(1)(a)(i) of the Rules applies in this case, since London Life stated that there was no debt owing or accruing under the life insurance contracts. ... They group support and other rights exempt from seizure, as well as compensatory allowances, under the category of personal patrimonial rights (since creditors have no right in the pledge in respect of those rights). [35]            It is interesting to note that the rights declared to be personal rights by the classical case law are no longer unanimously considered as such. ...

The relative effects of ordinary meaning, context and purpose on the interpretive process may vary, but in all cases the court must seek to read the provisions of an Act as a harmonious whole. [52]            In deciding how to interpret subsection 315(1) of the Act, it is necessary to examine the context of the Act and to find a meaning that is harmonious with the Act as a whole. [53]            Subsection 300(1) of the Act provides that: 300.(1) After making an assessment, the Minister shall send to the person assessed a notice of the assessment.  300.(1) Une fois une cotisation établie à l’égard d’une personne, le ministre lui envoie un avis de cotisation. [54]            This confirms that there are two separate processes – the assessment of a person and the sending of notice of the assessment to that person. [55]            However, in this case there is no indication that the Federal Court Judge considered subsection 335(11) of the Act in reaching his decision on the interpretation of the Act. ... Johnson, it should be considered to be valid. However, this simply means that an invalid RTP was served on the RCMP. ...

The Appellant as such considered that the Notice of reassessment under appeal entailed an overall disputed tax debt that exceeded the amount of $150,000 referred to in Schedule II of the Tax Court of Canada Rules (General Procedures [sic]) being a minimum of $467,786 in the aggregate (being, the tax liability under Part I in the amount of $46,810 and under Part III in the amount of $420,952); 8.       ... Consumers’ Gas Co., [1987] 2 F.C. 60, [1987] 1 C.T.C. 79, the total amount in issue is not the amounts that were considered or determined in the process but rather the final product of the process. [29]         Here, the Part III tax was the object of a proposed assessment only, and even though it had been the object of a determination by the Minister, it was not at issue in the appeal before me, which appeal was filed pursuant to subsection 169 of the ITA against the assessment issued for the 2005 taxation year. ...

The Minister also noted that Goodyear had had numerous opportunities to present evidence supporting its position and to challenge the data on which the screening assessment was based, all of which had previously been considered during the consultation process. [3]                Goodyear commenced an application for judicial review, contending that the Minister’s decision not to convene a board of review was unreasonable and that the manner in which it was reached breached a duty of procedural fairness owed to Goodyear. ... Section 64 of the Act provides that a substance is considered toxic if it is entering or may enter the environment in a quantity or concentration or under conditions that are or may be harmful to the environment or its biological diversity, or that constitute or may constitute a danger to human life or health or the environment on which life depends. [9]                A determination of toxicity originates, for present purposes, with the mandate under section 66 of the Act requiring the Minister to maintain a Domestic Substances List identifying substances which were in Canadian commerce, used in commercial manufacturing, or manufactured or imported into Canada in an amount not less than 100kg in any year from January 1, 1984 to December 31, 1986. ...

This should not be considered an exhaustive list and the CRA reserves the right to amend, change, add or delete individuals as the interview process progresses. ... The auditors just want to understand the business and do so by asking questions when they do a general audit. [22]            If proportionality is considered, the Minister suggests that the request for only 25 of Cameco’s many employees is not unreasonable. ...

It is clear from both Day’s evidence that he considered McLeod and Mongos as interchangeable as did McLeod who kept insisting he was the director and shareholder of Mongo’s when posed questions that challenged Mongo’s entitlement to any management service fees. ... While proceeds of sale clearly work into the calculation of profits due to recapture of depreciation, sale of good will etc., there was no indication the proceeds of sale were considered profits in their entirely. ...

The Dannea’s fees for this service was a 7% fee. [11]          The funds withdrawn from the Dannea’s bank account in any given year, were considered to be loans to the appellant as evidenced by a promissory note dated December 31 of the given year. ... In my opinion, it is a benefit conferred on the shareholder of the corporation which was rightly assessed by the Minister pursuant to subsection 15(1) of the Act. [37]          The appellant alleged that the amount of $12,173.75 should have been considered as a deductible business expense but he did not explain what he has done with the money. ...

The question of when a debt is to be considered uncollectible is a matter of the taxpayer’s own judgment as a prudent businessman. ... Fisher described how this determination should be made: For the purposes of the Income Tax Act, therefore, a bad debt may be designated as the whole or a portion of a debt which the creditor, after having personally considered the relevant factors mentioned above in so far as they are applicable to each particular debt, honestly  and reasonably determines to be uncollectable at the end  of the fiscal year when the determination is required to be made, notwithstanding that subsequent events may transpire under which the debt, or any portion of it, may in fact, be collected. ...

It stated in part that CCA grants were considered taxable income and T4A forms would be issued in respect thereof. [8]   The Appellant testified that she had a business called “b.h. ... (as he then was) considered a somewhat analogous situation in which the taxpayer, a professor on sabbatical, claimed expenses as being on business account. ...

To make this finding, the Decision was based on the definition of “advertising” in the CPTC Program Guidelines, which was published on April 2, 2012, by CAVCO in compliance with subsection 125.4(7) of the ITA [the Guidelines]. [19]   The Decision states the following: [translation] “Thus, any production that, like VILLAS DE RÊVE (I), offers i) a detailed description of the services, activities or products of any supplier whatsoever, ii) a detailed description of the main characteristics of the services, activities or products of the supplier in question, and iii) laudatory comments regarding those services, activities or products of such a supplier, is considered by CAVCO to be ‘advertising’ in nature, a category that is ineligible for CPTC. ... Their reply was sent to CAVCO on January 26, 2016, and was considered by the members of the Compliance Committee during two meetings, on February 18, 2016 and June 29, 2016. [30]   Although I have found that the Minister satisfied the requirements of procedural fairness, I will respond to Serdy’s claims. ...