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And later, on the same page,... a fine or penalty cannot be considered to have been incurred for the purpose of producing income unless in all the circumstances the incurring of the fine or penalty must be seen as an unavoidable incident of carrying on the business. ... The fine imposed by subsection 239(1) cannot be considered to have been incurred for the purpose of producing income unless it can be proven-and it was not- that in all the circumstances the incurring of the fine was an unavoidable incident of carrying on the business. ... This is so, but in allowing the expenses the Minister, I assume, considered the amounts to be employees’ wages. ...

., does not say that the evidence given on the review cannot be considered in deciding whether the deponent had the requisite state of mind for an authorization. ... Probative evidence on that issue, whether from his affidavit or from his testimony, must surely form a part of the total circumstances to be considered. ... However, when considering the second and third branches of s. 24(2) analysis dealing with the seriousness of the breach and long-term effect on the administration of justice, the trial judge considered all of the relevant circumstances and there is no indication that he placed undue weight on any one in particular. ...

Since they had no such discretion, they considered that the money in question could not be regarded as an “allowance” under s. 56(12) of the Income Tax Act (“the Act”), and so did not have to be included in their income pursuant to s. 56(1)(£>), (c) or (c.l) of the Act. ... She relied on the writers Driedger [11] and Côté [12] as a basis for the proposition that it is preferable to adopt an interpretation that gives effect to the provisions of the Act as a whole, which she considered could be done without even having to depart from the ordinary meaning of the words used. ... For the purposes of paragraphs 56(1)(b), (c) and (0.1) and 60(b), (c) and (0.1) an “allowance” will not include any amount that is received by a person unless that person has discretion as to the use of the amount, This provision is subject to subsections 56.1(2) and 60.1(2) which, under certain conditions, deem amounts which are not otherwise considered allowances to have been paid and received as an allowance. ...

His background and his other land dealings in those years are relevant facts to be considered in determining the Appellant’s intention with respect to the two properties in issue. ... The Appellant was familiar with one such residence situated at 102 Water Street, considered it to be worth saving and brought it to White’s attention. ... In reaching this conclusion, I have reviewed the documents filed as exhibits and the testimony of the Appellant and White in light of other proven facts and have considered such matters as, inter alia, the time-frame involved and White’s financial condition. ...

I do not propose to review the evidence in great detail, but I have considered all of it in the course of preparing this ruling. ... The matter has been considered by a number of courts. In Le Comte v. British Columbia, March, 1990, Viet. ... I have considered all of the material placed before me and have concluded that this issue is not as critical as it seems at first glance. ...

Iris asserts that the decision is procedurally unfair, an abuse of process and that the Minister improperly considered related proceedings between it and the Minister involving GST/HST rebates. ... Collateral factual findings related to the admissibility of the evidence are entitled to deference (Collins at para. 51). [21] The Federal Court therefore erred in applying the palpable and overriding error standard of review to the Prothonotary’s decision whether to admit the affidavit. [22] In rejecting the affidavit, the Prothonotary considered that the affiant had no personal knowledge of the decision, could not identify who was involved in the decision, could not explain why the decision was not communicated on the date it was made and did not personally assess any of Iris’ revenue in any of the qualifying periods. ... Iris seeks an order: requiring the Minister to pay Iris’ CEWS in the amounts claimed, for a total of $605,714; declaring the amount of the revenues to be considered in the calculation of the CEWS are the revenues reported by Iris; and C. requiring the Minister to issue notice(s) of assessment or notice(s) of determination in respect of the periods commencing March 15, 2020 and ending June 6, 2020. [43] The relief sought makes clear that the essential character of the notice of application is a challenge to the correctness of the finding that no “amount” is payable by way of a refund under subsection 125.7(2) and to vacate the notice of determination. ...

The request was made pursuant to subsection 19(1) of the Financial Administration Act of British Columbia on the grounds that “great injustice or great hardship to a person has occurred or is likely to occur”. [3] The CRA considered the Applicant’s request under section 23(3) of the Financial Administration Act, RSC 1985, c. ... The Committee also considered a remission of GST/HST owing for the period ending December 31, 2019. ... The Decision noted that in order for the Applicant’s health problems to be considered an extenuating factor for remission purposes, “there should be a direct correlation between an illness and a taxpayer’s inability to meet his or her tax obligations, as well as appropriate substantiation to support such a conclusion”. ...

We have completed your request and have carefully considered all the information to support your CRB eligibility. ... The Officer also states that in the course of his review he considered the listed documents and information, he reached a stated conclusion and that he recorded his findings in the SA Notepad and in the Second Review Report and that his entries on the SA Notepad can be identified by his user number “VJM953”. ... Further, that he had recently been able to obtain from his bank documentation that established that the source of the payments was from that person. [26] The difficulty that the Applicant faces is that those records which he states demonstrate the source of his income were not before the Officer and, therefore, could not have been considered by the Officer. ...

Barrs’ appeal because that issue was not considered in Belchetz. [6] For the reasons that follow, I would grant this appeal, without costs, on the terms set out below. ... In it, the independent third-level review officer considered only one aspect of the claim for equitable treatment made on behalf of Mr. ... Barrs was not considered by the independent third-level review officer. ...

[32] As I will explain, the appellants’ submissions, considered together or separately, do not affect the Federal Court’s conclusion that the contemplated seizure is reasonable for purposes of s. 8 of the Charter. ... Contrary to the appellants’ submissions, the Impugned Provisions were designed to address a risk within Canada and better the lives of people in Canada. [39] In Southam, the Supreme Court instructed that the relevant state interest to be considered under s. 8 of the Charter is “its rationality in furthering some valid government objective” (at page 157). ... An example was provided of a spouse of a U.S. citizen resident in Canada. • Affected persons are compelled to provide information to Canadian financial institutions. • U.S. citizenship is difficult and expensive to renounce or relinquish. • The provisions are heavy-handed compared to the soft administrative approach of voluntary disclosure programs maintained by the Internal Revenue Service. [61] In the Federal Court’s detailed reasons, the Court considered many concerns of this nature. ...