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The appellant requested more information from the CRA in respect of the proposed reassessment and, by letter dated August 24, 2012, the CRA advised the appellant that:   (a)        the $6 million loan was a shareholder benefit or an indirect payment for the benefit of the appellant resulting in an income inclusion under subsections 15(1) and 56(2) of the Act;   (b)        interest deductions were being denied as no amount of interest was paid or payable in the year; and   (c)        the CRA considered the $6 million loan to be a sham.   12.       ...

Each of these two conditions will be considered in turn.   Existence of a transfer   [27]         In this appeal, the Property seems to be have been transferred twice:   (a)     On December 14, 2007, pursuant to the Deed of Sale, Ms.  ...

F-7 regarding a decision made by Yvan Bélanger, Trade Policy Services Officer (the officer) at the Canada Border Services Agency (CBSA), on February 9, 2005, in which he denied the three applicants’ drawback claims, which were considered incomplete ...

In my assessment, the fundamental principle enunciated in the Salomon case remains good law in Canada and "One Man Corporations" should be considered as separate entities from their major shareholder save for certain exceptional cases. ...

That is- I'm 100 percent sure that is the day that I was considered served- Q:             The letter- A:            - the day you- Q:             The letter from Mr. ...

(b)        All GST amounts collectible [12]            After hearing argument from counsel for the applicants on the major issue whether the Minister's delegate had erred in the manner he calculated the applicants' net tax for rebate purposes and having considered the matter overnight, counsel for the Minister informed the Court the next day she had instructions to consent to this Court issuing an order quashing the Minister's reassessments (or determinations) in respect of each applicant's GST rebate application. [13]            She conceded the Minister's delegate had erred when calculating each of the applicant's net tax as defined in the Remission Order. ...

However, the Communiqués are administrative policies and were not issued pursuant to a discretionary power and may only be considered as concessions made by the Minister to resolve inequities within the Act. ...

In other words, "jurisdictional error"is simply an error on an issue with respect to which, according to the outcome of the pragmatic and functional analysis, the tribunal must make a correct interpretation and to which no deference will be shown. [16]            The factors to be considered in a pragmatic and functional analysis of the decisions in question here would involve consideration of the following issues: 1-       Presence of a privative clause: there is no privative clause in the Customs Tariff Act which would shield decisions of the Minister from judicial oversight. ...

Stickle. [24]       I have considered that Mr. Sawatzky, who was assisting Mr. ...

Villett confirmed that correspondence from Revenue Canada to Capitol Records, throughout the relevant period, reflected no suggestion that Revenue Canada considered Capitol Records and Kensington to be a single economic unit or that sales or transfers between the two companies should be ignored by virtue of the relationship between them. [12]      Mr. ...