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If no such settlement was reached, the Board had a discretion to pay the claimants such amount in settlement as it considered just and equitable. ...

I have also considered Re Drummond Estate; Minister of Finance for British Columbia v. ...

For 1945 the "reserve" of $13,230.07 was arrived at by adding together the profit element which it had lost on all the goods which had been returned to it in the last three months of the 1945 fiscal period, it being considered that the same percentage of goods delivered in the fiscal year of 1945 would be returned after January 31, 1945, and that the precise number of such returns would not be accurately ascertained until three months of the new fiscal year had elapsed. ...

Both were considered computers. [37] Apart from the question as to personal usage of, in particular the Apple Watch, both claimed Apple products are viewed by the respondent to be capital assets, and hence not deductible as claimed. ...

The Court has considered four options. The first is to seal the entire file. ...

In Jabel Image Concepts Inc v Canada, [2000] GSTC 45, the Federal Court of Appeal wrote at paragraph 12: When an Act uses different words in relation to the same subject such a choice by Parliament must be considered intentional and indicative of a change in meaning or a different meaning. [22] In the case of paragraphs 254(2)(b) and (g), it must be presumed Parliament intentionally chose to make a distinction when it used the words “primary place of residence” in paragraph (b) and “place of residence” in paragraph (g). ...

He wrote as follows: [50] The subjective nature of the wilful blindness standard also means that the personal attributes of the individual may be considered in determining whether the individual is wilfully blind. [51] In contrast, the objective nature of the gross negligence standard means that the personal attributes of the individual are not relevant unless the individual establishes that he or she is incapable of understanding the risk the individual has failed to avoid (see R. v. ...

The reviewing court must refrain from “reweighing and reassessing the evidence considered by the decision maker”: Vavilov at para 125. [19] A reasonable decision is one based on an internally coherent and rational chain of analysis and that is justified in relation to the facts and law that constrain the decision maker. ...

Konlambigue submits that she provided all the evidence necessary to show that she had earned more than $5,000 as a self-employed worker in 2020 and that the decision fails to explain why the officer considered this evidence to be insufficient. ...

The reason cited by the officer in her decision letter is the following: [translation You did not earn at least $5,000 (before taxes) of employment or net self-employment income in 2019 or 2020 or in the 12 months before you first applied;... [11] To arrive at this conclusion, the officer considered all of the representations made by Ms. ...