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The letter indicated that the Applicant’s 2019 tax return would be considered along with any other information provided. [10] On July 8, 2022, the Applicant received a further letter, this time requesting documentation in connection with his CRB payments. ... As a result, the documents attached to the Applicant’s Affidavit are inadmissible and will not be considered. ... This includes establishing both the quantum and the source of the earnings. [28] The letters set out the types of documents identified in the Guidelines, which serve as acceptable proof, including: ● Invoice(s) for services rendered that include the service date, who the service was for, and the name of the individual or company ● receipt of payment for the service or services provided (a statement of account or bill of sale showing a payment and the remaining balance owed) ● documents showing income earned from a “trade or business” as a sole proprietor, an independent contractor, or a partnership ● any other document(s) that will confirm you earned $5,000 in employment or self employment income [29] In this case, the Second Reviewer’s notes demonstrate that they considered all the documents and information provided by the Applicant. ...

A decision should only be set aside if there are “sufficiently serious shortcomings” such that it does not exhibit the requisite attributes of “justification, intelligibility and transparency”: Vavilov at para 100; Mason at paras 59–61. [8] In his written submissions, the Applicant argued that the CRA officer’s decision was unreasonable for three reasons: (i) the officer’s calculation, both in terms of interpretation and application, is unintelligible; (ii) the officer fettered their discretion by relying on the CRA Guidelines for determining the relevant calculation, as opposed to undertaking their own statutory interpretation, thereby frustrating the statute’s purpose; and (iii) the decision lacks justification as it does not discuss the Applicant’s interpretation of the calculation. [9] Furthermore, at the hearing, the Applicant raised a new legal argument for the first time, namely that the officer should have considered whether he had any foreign income in the relevant time frame prior to coming to Canada. ... Paragraph 3(1)(f) of the CRB Act sets out the 50% reduction of income requirement that was applied in this case: 3 (1) A person is eligible for a Canada recovery benefit for any two-week period falling within the period beginning on September 27, 2020 and ending on October 23, 2021 if 3 (1) Est admissible à la prestation canadienne de relance économique, à l’égard de toute période de deux semaines comprise dans la période commençant le 27 septembre 2020 et se terminant le 23 octobre 2021, la personne qui remplit les conditions suivantes: […] […] (f) during the two-week period, for reasons related to COVID-19, other than for reasons referred to in subparagraph 17(1)(f)(i) and (ii), they were not employed or self-employed or they had a reduction of at least 50% or, if a lower percentage is fixed by regulation, that percentage, in their average weekly employment income or self-employment income for the two-week period relative to f) au cours de la période de deux semaines et pour des raisons liées à la COVID-19, à l’exclusion des raisons prévues aux sous-alinéas 17(1)f)(i) et (ii), soit elle n’a pas exercé d’emploi — ou exécuté un travail pour son compte —, soit elle a subi une réduction d’au moins cinquante pour cent — ou, si un pourcentage moins élevé est fixé par règlement, ce pourcentage — de tous ses revenus hebdomadaires moyens d’emploi ou de travail à son compte pour la période de deux semaines par rapport à: (i) the case of an application made under section 4 in respect of a two-week period beginning in 2020, their total average weekly employment income and self-employment income for 2019 or in the 12-month period preceding the day on which they make the application, and (i) tous ses revenus hebdomadaires moyens d’emploi ou de travail à son compte pour l’année 2019 ou au cours des douze mois précédant la date à laquelle elle présente une demande, dans le cas où la demande présentée en vertu de l’article 4 vise une période de deux semaines qui débute en 2020, (ii) in the case of an application made under section 4 in respect of a two-week period beginning in 2021, their total average weekly employment income and self-employment income for 2019 or for 2020 or in the 12-month period preceding the day on which they make the application; (ii) tous ses revenus hebdomadaires moyens d’emploi ou de travail à son compte pour l’année 2019 ou 2020 ou au cours des douze mois précédant la date à laquelle elle présente une demande, dans le cas où la demande présentée en vertu de l’article 4 vise une période de deux semaines qui débute en 2021;   [11] This provision was considered by Justice Grammond in Saadi v Canada (Attorney General), 2024 FC 648 at para 14 [Saadi 2024]. ... I am unable to agree. [20] The CRA officer’s notes make clear that they considered the Applicant’s submissions that his 2019 income should be divided by the 24 weeks he worked, as opposed to by a 52-week period: Second Review Report, CTR at 10. ...

Chan considered that subsection 97(2) might be relevant to the ruling request. [55]            The next day Mr. ... Gouin-Toussaint that they considered this further consultation to be appropriate. ... Read's reference to a "position in society" was inappropriate and ill considered. ...

The function of this requirement is to remove from the ambit of the GAAR transactions or series of transactions that may reasonably be considered to have been undertaken or arranged primarily for a non-tax purpose.  ... For example, transactions that may reasonably be considered to have been undertaken or arranged primarily for family or investment purposes would be immune from the GAAR under s. 245(3).  ... The section is cast in terms of a double negative, stating that the GAAR does “not apply to a transaction where it may reasonably be considered that the transaction would not result directly or indirectly in a misuse... or an abuse”.   ...

Overall, he considered the 2012 budget reasonable. Mr. Michelin also noted that Deloitte considered it reasonable as well. ... Mady considered the figure to be at least within the realm of possibility. Deloitte, in doing the due diligence for DCC, considered the figure reasonable. ...

Overview [31]   The application of the GAAR to Partnerco will be considered first. ... The Tax Court was required to consider all three. [39]   The Court also considered the reasonable tax consequences for Partnerco if the GAAR were to apply. ... The Crown’s submissions will be considered first. (2)   Was there a tax benefit? ...

On the other, some decisions considered that the violation of section 18 of the Immigration Regulations, 1978, which is the equivalent of section 196 of the IRPR, did not automatically affect the general interest. [24] (ii) Line against the appellants’ position [62]   A series of Court decisions considered the interests protected by the IRPA to be of directive public order and that a contract of employment exercised by a foreign national without a valid work permit must be sanctioned by absolute nullity: Isidore v. ... But application of these principles has evolved over the years to meet changing needs and realities… Not all contracts which violate a law or regulation, however indirectly or theoretically, must be considered absolutely null. ... P‑40.1, is considered to be of protective economic public order as a whole in a number of decisions, such as: 9002‑5073 Québec Inc. v. ...

The alleged harm is already crystallized and can as such be considered imminent. ...   [120]   In addition, having considered the evidence presented by Mr. ... I also considered the question of justice and equity in agreeing to the interlocutory reliefs sought by Mr. ...

Other factors considered by the Provincial Treasurer were summarized by the defendant as follows. ... In so far as Dover Park was considered that was essentially the whole deal. ... The defendant concludes that the Provincial Treasurer made it clear in his direction letter that he considered the Alberta and Southern case and considered it not to be binding on his decision. ...

Choulli had developed in the Appellants’ case, and which would be considered by the GAAR Committee. ... The assertion that other analyses were not considered by the Minister’s auditors concerning the Appellants is possible, but not necessarily more likely than not. ... Situated as preamble overtures in the replies, frankly, features rather than diminishes such salvos. [149] The Respondent shall provide a description of the “strategies” and “opportunities” considered and a description by list of those ignored and irrelevant. ...