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Justice Walsh stated at page 5174: “This section is a general one, however, under the heading ‘Tax Evasion’ and I therefore believe it is necessary in any given case whether the company was merely incidentally gaining a tax advantage as the result of setting up a bona fide pension plan, or whether it would not have considered setting up this pension plan but for the tax advantage to be gained as a result thereof, and in the latter event Section 137(1) would be applied. ... A statement was made by my friend that depreciation may not be the type of loss considered under Section 137(1). ...

Even though section 13 of Exhibit A-1 cannot be considered strictly legal, it nevertheless constitutes incipient written evidence that the intention of the de cujus and Crown Life was to make, not the insured or his heirs, but W H Genest Lumber Enrg beneficiary of the insurance policy. ... There is no evidence to indicate that the legal heirs of the de cujus considered themselves the beneficiaries of insurance policy No 566034 or that they objected to the cheque for $34,511.13 being made out jointly to W H Genest Lumber Ltd and the bank. ...

The evidence of the auditor Mr Burstein is that the said loan was not included as a bad debt in the financial statements of the appellant company because it was still considered at that time to be a current and collectable account. ... He therefore considered all these loans to be adequately secured and felt that it would not at that time have been good accounting practice to set up a reserve, which would unquestionably, in his mind, have been challenged by the taxation officials. ...

(d) Subsequently, an unsolicited offer for the subject lands was received by the Appellant and his co-investors, which was considered reasonable and was accordingly accepted. ... He knew that North Vancouver had an unfortunate history of highrise building, but the location he had in mind on which to build the 108- suite apartment block was in front of a city park, guaranteeing a majestic and unobstructed view, and he considered it a perfect site on which to erect such a building. ...

I have observed him in the witness-box and have considered his demeanour in answering questions. I have considered the considerable interest he has in the outcome of this appeal. ...

A photocopy of this agreement is annexed hereto, and is to be considered an integral part thereof to have legal effect as if herein quoted in extenso. ...

[13] Paragraph 6(1)(f) of the Act requires that all amounts received by a taxpayer in a year that were payable to the taxpayer on a periodic basis in respect of the loss of all or any part of the taxpayer’s income from an office or employment pursuant to a disability insurance plan to or under which the taxpayer’s employer has made a contribution be included in the taxpayer’s income employment insurance benefits. [14] The WLRP benefit payments paid to an employee are considered to be employment income because they are paid in respect of an employment. The employees receive the benefits on a periodic basis for loss of employment income due to sickness, maternity or accident. [15] When benefit payments are made by a third party, such as an insurance company in this case, who is not the actual employer, the third party is deemed to be the employer because the actual employer is the party liable to pay its employees. [16] Pursuant to paragraph 153(1)a) of the Act, the person making the WLRP benefit payments is required to deduct or withhold from the payments the amount determined in accordance with prescribed rules for income tax purposes. [17] Paragraph 200(2)f) of the Income Tax Regulations (C.R.C, ch.945), stipulates that every person who makes a payment described in subsection 153(1) of the Act shall make an information return in prescribed form in respect of the payment and subsection 200(2) of the Regulations requires from every person who makes a payment as or an account of, or who confers a benefit or allocates an amount that is in paragraph (f) an amount payable to a taxpayer on a periodic basis in respect of the loss of all or any part of his income from an office or employment, pursuant to (i) a sickness or accident insurance plan (ii) a disability insurance plan or (iii) an income maintenance insurance plan, to or under which his employer has made a contribution, to make an information return in prescribed form in respect of such payment or benefit. [18] Considering the fact that the WLRP benefit payments paid to an employee by his employer or by a third party on behalf or his employer are considered to be employment income, they shall be reported on T4 slips by the employer. ...

Clarke requested relief for the 2010-2015 taxation years, the CRA only considered the 2010 and 2011 taxation years where interest had been applied. [7] The CRA credited Ms. ... The officer also found that the Applicant knowingly allowed a balance to exist, failed to take reasonable care in conducting her affairs, and failed to act quickly to remedy the delay or omission and therefore refused further relief. [10] In a decision dated January 26, 2021, the CRA team leader of the appeals branch of the Taxpayer Relief Centre of Expertise who considered the Second Level Review (“CRA Appeals Team Leader”) accepted the recommendation to partially approve the request. ...

M.N.R. case and it would be superfluous to repeat here the arguments and jurisprudence I considered in reaching the conclusions I did in that case. What must now be considered is whether there are any differences in the evidence as to the personal background and apparent intentions of the late Donald F. ...

That conclusion, however, would, in my view, be reached not because what was being considered was an extension of a previously existing mine but because on the facts as disclosed it could not by itself be regarded as a mine in the ordinary sense of the word. It will no doubt in every close situation become a matter of fact and degree whether or not what is being considered is a mine but to my mind the example I have put is far different from the present situation where all the elements necessary for a distinct mine appear to me to be present. ...