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Water that is removed from the crude by the separators is treated to reduce residual oil content to below or at levels that are considered to be protective of the environment as prescribed by government regulation prior to being released to the sea. ... It was then shipped either directly to a purchasing refinery or to Whiffen Head for subsequent shipment to a refinery. [51]   In the circumstances, I have no difficulty concluding that the transporting/transmitting of the crude from the GBS to the shuttle tankers was sufficiently connected with the marketing of the crude to be considered an integral part of the production of the crude for the purposes of paragraph 1204(1)(b) of the ITR. ...

When I questioned him regarding possible errors in his analysis, he considered my questions and, if my analysis had merit, readily accepted that changes should be made. [9]   Mr. ... Yet he neither reported that revenue nor the purported losses on lines 162 and 135 of his returns nor completed a T2125 Statement of Business or Professional Activities. [95]   If I am wrong and the single pages that Paul Buday attached to the returns showing losses are sufficient for Paul Buday to be considered to have reported the business in his returns, then I find that he made omissions by claiming losses in a business that was clearly profitable. ...

He considered it to be a conclusion of law “that has no place among the Minister's assumed facts”. [25] I agree that legal statements or conclusions have no place in the recitation of the Minister's factual assumptions. ... Therefore, after having considered the evidence in respect of the Apple store policy, the purchasing patterns, the distinction between void and voidable contracts, and the doctrine of common law illegality, I am satisfied that Lohas could grant authority to the buyers allowing the agent to affect Lohas’ legal position. ...

In addition, the CRTC evidently considered s. 9(1)   (h) in its context, including not only the objectives of the Broadcasting Act   but also its broader statutory framework. ... We agree with the Attorney General of Canada’s submission that the CRTC’s reasoning here engaged its specialized and technical knowledge, leading to an interpretation that was reasonable in this operational context. [95]                           In addition, the CRTC evidently considered s. 9(1)   (h) in its context, including not only the objectives of the Broadcasting Act   but also its broader statutory framework. ...

The Queen, [1985] 2 C.T.C. 79, 85 D.T.C. 5310, the Federal Court of Appeal considered the issue of a taxpayer corporation engaged in the business of building logging roads and performing related site services under contract with owners of logging rights, and an investment tax credit claimed on equipment purchased for such use. ... Canada, [1990] 1 C.T.C. 134, 90 D.T.C. 6096, Martin J. of the Federal Court-Trial Division considered the matter in which the taxpayer acquired a diving support vessel and chartered it to Petro-Canada the same day for use in offshore exploration and drilling for petroleum. ...

And that would have been the only section under which I might have considered giving particulars because I find that is paragraphs A and B. ... Oley cannot be considered to be entirely straightforward. In these circumstances I have difficulty in concluding and cannot accept that the documents that had been seized from Mr. ...

It is generally considered that the cost amount of Canadian resource property which is distributed on the dissolution of a partnership is nil. ... From its point of view the contractual obligation was absolute, and the contractual obligation must be considered and the word “agreement” interpreted from its point of view. ...

Here the defendant was able to explain his evidence by stating that he was not an accountant; the Court considered him to be an honest man and as such he was not avoiding taxes or deliberately filing false returns but simply did not know what he was doing. ... In my review of the evidence, I have considered the very cogent argument of the Crown in addressing the issues raised by the defence witnesses; in particular the evidence of Mr. ...

There are a variety of manuals outlining how to manage ADHD children and medication is sometimes considered appropriate. ... C.A.), the Northwest Territories Court of Appeal considered the meaning of the word “certify” as it appeared in the Canada Evidence Act. ...

JP Morgan, at para 82. [119] Although the Federal Court of Appeal’s decision in JP Morgan considered assessments under the Income Tax Act, the analysis with respect to judicial review applications is equally applicable to the GST provisions of the Excise Tax Act: Johnson, at para 21. ... (At the hearing, the Minister’s counsel recognized that the “decision” could be considered to be more than one decision for the purposes of Rule 302 of the Federal Courts Rules, but did not pursue the point on this motion.) [121] Grounds for Judicial Review: The first Notice of Application pleaded that CRA’s proposal letter dated March 16, 2021, proposed to deregister Newave’s GST/HST program account, disallow input tax credits and assess gross negligence penalties. ...