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I have considered your suggestion that possibly the Minutes of Judgment of the Tax Appeal Board could be amended to refer the assessments back to the Minister for re-assessment. ... This question was considered by the Supreme Court of Canada in the case of Paper Machinery Limited et al. v. ... Kelsey on behalf of the appellant, whether or not the Minister would have been willing to re-assess Gunnar if he had considered himself duly empowered to do so under the Act. ...

Fortin's income by the Minister, who considered that Mr. Fortin had appropriated those amounts to his own use, and Mr. ... An amount of $2,326 for December 1987 was not considered since the payroll journal for the full year was not available as a result of a fire. ... Having admitted through their counsel that they received the amounts that the Minister considered to be appropriations, Jean-Guy Fortin and Mrs. ...

.), for example, the appellate courts considered only the inherent jurisdiction of courts of original jurisdiction. ... New searches were made for documents where subsections “69(5) and 245(2)” of the Act were considered. ... The issue of confidentiality was considered by me, although not argued before me. ...

It does not hold that in a case where the company in issuing shares as a stock dividend does not at the same time commit itself to immediate redemption its acts can be considered as anything else than capitalization of income. ... The opinion given to the shareholders, resident in the United States, is something which must be considered, as is the fact that the trustee controlled the company. ... Besides the cases referred to in these reasons and the numerous cases considered in those various decisions, I have read with care the many other cases referred to in the arguments of counsel, not once but several times. ...

ANALYSIS (a) Morrison and Eisbrenner [17] In Morrison, the Tax Court of Canada considered the denial of charitable donation tax credits claimed by Mr. ... Morrison’s appeal with respect to the charitable donation tax credit for participation in the CGI Program. [20] In Eisbrenner, the Federal Court of Appeal considered the appeals by Mr. ... The Tax Court considered whether the “inflated tax receipt” for the CHT in-kind donation vitiated Mr. ...

Phipson contended that they were profits, because when the value of money and the effect of such a protracted period of payment are considered, we could not assume that the value of the planitif’s moiety was more than some £23,000, and that the rest must be considered as profit, and that it was the fault of the plaintiff that she has so mixed up profits with capital that they cannot be distinguished; and that therefore the whole must be liable to income tax: But there is nothing on this record to shew that the property was not worth more than £99,000, nor is there anything to shew that the postponement of payment was not a mere indulgence on the part of the seller. ... Such a use is not that contemplated by the Act; the use thereby considered is of something that of itself produces. ... The question of what constitutes receipts "‘like royalties’’ was considered by Mr. ...

In 2015, the Applicant submitted a disclosure application under the Voluntary Disclosure Program [VDP] of the Canada Revenue Agency [CRA], after it considered it might be deemed a Canadian resident for income tax purposes under the Income Tax Act (R.S.C., 1985, c. 1 (5th Supp.)) ... Importantly, the VDP is not intended to serve as a loophole through which taxpayers evade their tax obligations: see VDP Information Circular at paras 8-9. [18] According to the VDP Information Circular, to be considered valid, a taxpayer’s VDP disclosure must be, among other things, voluntary, meaning, it must not be initiated in response of, for instance, a CRA enforcement action, and it must include information that is complete and accurate. [19] If the Minister, through a delegated VDP officer, finds that the disclosure meets the VDP conditions, it will be considered a valid and complete disclosure and the taxpayer will be required to pay taxes or charges plus interest, but will not be charged penalties or prosecuted with respect to the disclosure: VDP Information Circular at para 11. ... The Proposal Letter went on to state that the CRA considered the unreported investment income earned prior to 2003 material. [99] Attached to the Proposal Letter was “Appendix 2” that provided further explanations for the proposed adjustments. ...

The right to compete would not be considered "property" within the ordinary meaning of that word. ... (c) The jurisprudence [48]            I turn now to the jurisprudence that has considered the statutory definition of "property" and the meaning of the phrase "a right of any kind whatever". ... The facts and statutory provisions appear to be similar to those considered in this case ...

If after that process it is found that there is ambiguity about what was intended, parol evidence may be considered. ... Can the payment reasonably be considered to have been received as assistance in respect of an outlay or expense? ... The question of determining fair market value where only one side presents an expert was considered by Bowman, A.C.J.T.C. in Klotz v. ...

  (1)  Federal Court--Trial Division (1995), 60 C.P.R. (3d) 181 24                                As a preliminary matter, McGillis J. considered the nature of the proceedings before the court.  ... She also stipulated that, even had she not considered the extrinsic evidence given by Mr. ... None of the parol evidence considered by the Federal Court of Appeal has had any bearing on the conclusions I have reached ...