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This fact does not seem to have been considered by the CRA during its audit. [4]               [2002] RJQ 36, 2002 CanLII 41095 (QC CA). [5]               MacCallum v. ...

He concluded by saying that he had no strong argument to make in support of the penalties. [25]         I have considered whether Mr. ...

However, as discussed above, I am confident that the senior officials who considered whether this information could be disclosed would be well aware of the public interest values that would favour its release in these circumstances. ...

Konyi considered that Ms. Konyi’s dividend income from the family trust and her investments would be such during the course of 2006 that Ms. ...

If the context is properly considered, the Crown suggests, it is clear that the Terminal should not qualify for CCA at the rate of 30 percent. ...

[para. 23]…            [44]          It has been held that in drawing the line between “ordinary” negligence or neglect and “gross” negligence, a number of factors have to be considered: (a)      the magnitude of the misrepresentation in relation to the income declared, (b)     the opportunity the taxpayer had to detect the error, (c)      the taxpayer’s education and apparent intelligence, (d)     the genuine effort to comply. [45]          No single factor predominates. ...

The remainder of the reduction comprises makeup and hair and wardrobe expenses that were allowed by the Appeals Division because they were considered to have been incurred for business purposes. [10]          Below I set out in more detail the disputed expenses: Taxation Year Category Total Expenses Claimed Total Expenses Allowed 2009 (DE) Advertising $2,566 $2,566   Business Promotion $2,129 $1,006   Makeup/Hair $3,342 $1,671   Management/Chaperone $10,000 $10,000   Research and Development $1,554 —   Rent $2,010 $2,000   Travel $13,957 $4,261   Wardrobe $3,013 $1,506 2010 (DE) Business Promotion $1,378 $347   Makeup/Hair $1,518 $759   Management/Chaperone $14,000 $10,000   Research and Development $463 —   Rent — $4,000   Travel $3,209 $634   Wardrobe $2,659 $1,329 2011 (S) Automobile $2,753 —   CCA Automobile $2,576 —   Makeup/Hair $2,431 $1,251   Entertainment $2,618 $870   Research and Development $2,387 $148   Travel $13,158 $695   Wardrobe $6,414 $3,222 [11]          It should be noted that: –   The 2009 advertising expenses consist of purchases of gifts to the cast and crew of productions Mr. ...

But, the majority went on to find that a constitutional duty was owed, under the head of the “honour of the Crown”, and that the conduct of government officials a century and more ago in respect of the land allocation provided for in the Manitoba Act, 1870, had been so non-diligent as to fail to uphold the honour of the Crown. [19]          The majority then considered whether a Manitoba statutory general limitation provision should apply here, noting the constitutional context. ...

Règlement sur l’immigration et la protection des réfugiés, DORS/2002-227 Bad faith Mauvaise foi 4 (1) For the purposes of these Regulations, a foreign national shall not be considered a spouse, a common-law partner or a conjugal partner of a person if the marriage, common-law partnership or conjugal partnership 4 (1) Pour l’application du présent règlement, l’étranger n’est pas considéré comme étant l’époux, le conjoint de fait ou le partenaire conjugal d’une personne si le mariage ou la relation des conjoints de fait ou des partenaires conjugaux, selon le cas : (a) was entered into primarily for the purpose of acquiring any status or privilege under the Act; or a) visait principalement l’acquisition d’un statut ou d’un privilège sous le régime de la Loi; (b) is not genuine. b) n’est pas authentique.   ...

This issue was considered by the Court of Appeal (Civil Division) in Locabail (U.K.) ...