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The opportunities to provide information and documentation to the CRA, outlined above, were more than sufficient to be considered fair to R&S. ...

Also, the Appellant failed to provide a travel log to support his position. [56]         All things considered, I find that the Appellant has not demolished the Minister’s assumption on this point and I decline to disturb the conclusion reached. ...

Yet that simply carries on a long-standing regime under Customs Acts of the past, at least in relation to goods seized, for the goods are forfeited to Her Majesty at the time of the contravention of the Act (s. 122), and terms of any remission, where the Act or regulations are contravened, have been considered beyond the role of the Court to review. ...

The same cannot be said for a dividend refund which is an amount that is available for a monetary refund or credit where certain conditions are met. [32]         The context for the phrase “dividend refund” must be considered in conjunction with Part IV tax. ...

What remain more clear, or at least consistent with the generally received notion of a transfer, are the elements or actions required of the transferor: the commission of an act or execution of a document divesting the transferor and investing the recipient with the property [3], the identification of some memorialized event or document which has the legal effect of conveyance [4] and the contemporaneous placement of that action at the time the tax debt is owed [5]. [22]         Within the context of considering whether a transfer occurred there are three sub-issues to be considered; (i) the application of section 84(2): deemed dividend on winding-up; (ii) the effect of the Notice of Dissolution: Section 241 of the OBCA; (iii) apart from the legal subsistence of CIA after the Dissolution Date, did actions occur which constitute a transfer within section 160. ...

Mazo initially filed her Notice of Appeal on the basis of what have been described as organized pseudo-legal commercial arguments, she did not rely on such arguments in filing her tax returns. [17] Thus, I have not considered her belief in those arguments when determining whether she was grossly negligent in failing to report her income. ...

The reassessment is therefore correct. [41]         Beyond this conclusion, there is nothing factually to suggest that at or before the closing date, the asserted Beneficial Owners, Bazis YYC or Plazacorp were considered by the Appellant as obligated to pay the consideration or face suit for failure to do so. ...

It strains my sense of what could be considered reasonably probable. [43] The Appellant was in fact aware that he had to pay taxes on income earned in Canada. ...

Following this disposition the appellant made an election in accordance with to s. 83(2) of the Act regarding a capital dividend of $612,930, which was paid tax-free to its shareholders. [3] In assessing the appellant the Minister considered that the gain made was not a capital gain but business income. ...

., (supra) the Federal Court of Appeal laid out certain matters which should be considered by this Court when hearing these appeals. ...