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There are no similar documents for Objectives 2 and 3. [72]   As a result, I cannot conclude that any of the documents provided by National can be considered contemporaneous documentation that details any of the tests and the results of those tests. [73]   While it is not mandatory that the evidence be documentary, and testimonial evidence may be presented, I did not find that Mr. ...

Each time that Global paid one of the above dividends, the amount that Global was liable to pay under the ITA in or in respect of the particular taxation year or any preceding taxation year exceeded the amount of the dividend. [5]   In its Notice of Appeal, the Trust admitted that: a) during the taxation years in question, the Trust did not deal at arm’s length with Global; b) the Trust received dividends from Global at times when Global was liable to pay one or more amounts under the ITA; and c) each time that Global paid a dividend to the Trust in 2000, 2001 and 2002, the liability of Global to pay one or more amounts under the ITA exceeded the amount of the particular dividend. [3] As the Trust did not give any consideration to Global for the dividends paid in 2000, 2001 and 2002, the only question to be resolved in this Appeal relates to the fair market value of the dividends at the time that they were paid by Global to the Trust. [6]   At the hearing, Kim Moody, the accountant for the Trust, testified that, when preparing the income tax returns of the Trust and Riaz and Zainool Mamdani for 2000, 2001 and 2002, he considered various scenarios in order to determine whether the Trust should include the entire amount of each dividend in its income or whether it would be advisable to allocate some of that dividend to one or more of its beneficiaries. [4] He testified that, if the only income of the Trust in 2000, 2001 and 2002 were the taxable dividends in question and if no portion of those dividends were allocated to beneficiaries, the aggregate amount of federal and provincial income tax that would have been payable by the Trust would have been as set out in three mock income tax returns (as he called them), which were entered into evidence. [5] During the course of Mr. ...

Specifically, he found that the mutual set-off gave rise to a surrender of a debt without consideration because the Oldco note had a negligible value in comparison to the Newco note. [61]   The appellant’s argument that the Tax Court judge ought not to have considered this issue without first inviting the parties to comment on it is somewhat moot at this stage, as both have now had the opportunity to address it. ...

This final account is being rejected, and not being considered in any way in settlement of the building portion of this loss. ...

In Hryniak v Mauldin, 2014 SCC 7 (Hryniak), the Supreme Court of Canada considered the values underlying the summary judgment process. ...

I emphasize the word “all” in the previous sentence because, although judicial independence is usually considered and discussed in terms of the relationship between the judiciary and the executive branch, in this appeal the relevant relationship is between the judiciary and Parliament. ...

The following criteria should be considered: the profit and loss experience in past years, the taxpayer’s training, the taxpayer’s intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...

All items currently reclassified were already considered as I.T.C. eligible on previous reassessment. ...

Meanwhile Kondrat considered his wife to be uncooperative and thought that "if Karon could pay her something she’d release against Karon”. ...

Intricate intercorporate and personal relationships are a way of life these days, and it would be naive to suggest that the tax implications of these relationships are not considered whenever they are created. ...