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A decision will be made after these documents have been considered. The reasons for the subject’s placement in segregation are still current. ... It will have to return the file so that this issue is considered by Ms. ... Fraser had considered these issues to determine whether the seventy (70) day retention in segregation was justified and whether the explanations given were sufficient, considering the circumstances. ...

You considered requesting a Waiver from the Taxpayer. Your Team Leader, Charles Thompson, however, stated that CCRA's policy is not to request a Waiver to extend the audit period. ... Justice Rothstein summarized the guiding principles with respect to subsection 231.2(1) as follows, at paragraph 17: Having considered Richardson and McKinlay, I conclude: 1.              ... They also appear not to have fully considered our concerns regarding the reasonableness of the fees for which there was almost no support, proof or affirmation. ...

Chris Magnone, to advise them that the Letter of Credit of March 31, 2009 was not considered an acceptable security. ... The Letter of Credit was not considered security satisfactory to the Minister.   ... The stages of this legislative scheme have been duly considered by the Federal Court of Appeal, in Canada v. ...

Each taxpayer relief request is considered on its merits (Maple Lodge Farms Ltd. v. ...   [44]            Furthermore, the Minister considered all of the information before him and considered no irrelevant information in arriving at his decision. ...   [47]            The applicant has not demonstrated how the CRA’s assessment was in error. [48]            The respondent considered all the applicant’s arguments and the particular facts of the case in making its decision when reviewing the applicant’s appeal. ...

At this time, they considered how they might preserve the PUC of the shares of VHHC Holdings. ... The issues raised by the parties must be considered in light of these requirements.   ... In this regard, PUC may be considered as one means of financing all or a portion of the acquisition of the property of a corporation. ...

The question remains whether the relief should be granted. [67]   I note that this proceeding differs from the motion considered in Boulachanis v Canada (Attorney General), 2019 FC 456, a decision brought to my attention by Applicant’s counsel after the hearing. ... Toutsaint, he was never concerned about the risk of suicide to the point that he would have considered it to be of imminent danger. ... While that in itself was considered serious and required intervention, the medical staff was confident that it could be managed. ...

Justice Hogan of this Court held that because the taxpayer had taken “a thoughtfully considered position”, the Minister was not entitled to reassess beyond the normal reassessment period even if she took a different position. ...   [80]   In  Savard v The Queen, [6] this Court again stated that taxpayers have the right to disagree with the Minister in their interpretation of the Act, without this necessarily being considered a misrepresentation. ... In other decisions, the Court considered that successive sales should be treated as giving rise to business income (see Cayer v The Queen [9]). [86]   The question that I have to decide is whether Mr. ...

A property does not need to be generating income at every stage of operation in order to be considered a source of income. ... Ultimately, whether an expense is incurred on account of income or capital is a determination that can only be made after the facts have been considered in full. ... In arriving at my conclusion, I have considered the following factors in light of the entirety of the evidence. i) Betterment and Enduring Benefit [35] In the instant case, the repairs did result in a betterment or improvement to the unit which was of enduring benefit. ...

The applicability of the Convention to effect a reduction in the rate of withholding tax from 25 per cent to ten per cent depends upon whether Norsk, the recipient of the rental payment, can be considered to be a resident of the United States for the purposes of the Convention. ... The appellant submits that it is implicit in the Convention that only those corporations that are liable to taxation on all of their worldwide income can be considered resident. ... It is apparent that if the qualifying clause, supra, had been included in the Convention in issue, Norsk could not possibly be considered a resident for the purposes of this Convention. ...

Le is considered a "dependent contractor" within the meaning of the Canada Labour Code and that the appellant is a federal business to which the Canada Labour Code applies does not alter this conclusion. ... Le, is considered an employee within the meaning of the Canada Labour Code (subsection 3(1)), this does not necessarily mean that he will be considered an employee within the meaning of the C.C.Q. ... Le therefore cannot be considered an employee of the appellant. Training [72] The respondent also argued that there were elements related to training that revealed the existence of an employer-employee relationship. ...