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Paragraph 18(1)(m) of the Income Tax Act might well be considered as an "appreciable change". ... On the other hand, defendant's argument that to uphold plaintiff's action to be allowed to continue to deduct royalty payments prohibited by paragraph 18(1)(m) on the basis that this infringes the Tax Convention, unless at the same time the judgment finds that subsection 124(2) cannot be applied to plaintiff, and to allow it to claim the 15 per cent deduction from profits allowed therein, would defeat the purpose of the amendments considered as a whole and the intent of the Act, is considerably weakened by another section of the amended Protocol and by other jurisprudence. ...

Having finally disposed of all matters raised during those two days of hearings, including the two applications for show cause orders and the award of costs in relation to those applications, I now direct that costs be awarded to Her Majesty in relation to all other matters considered on October 23 and November 19, 1996, in a fixed sum $2,500.00, payable by the plaintiff Mary David in any event of the cause. ... It will assist in explanation of my Order for costs if the background is briefly described and if the various motions considered on October 23 and November 19 are reviewed with summary reasons for their disposition.          ...

It should also be noted that the letter of assignment shall be considered to not be in force after the expiry date of the application, after the cancellation date of the application or after the date the applicant named in the application goes out of business.               ... Government of Canada 3, the Supreme Court of Canada considered the role of policy guidelines in the context of the Export and Import Permits Act 4. ...

  [7]                In the Court’s appreciation of the parties’ positions, the following grounds are to be considered under this motion:                                                                i.       ... The SJPA submits that the licencing of a seasonal retail boat service under consideration in this application is materially indistinguishable from the activities considered in DRL Vacations and in 54039 Newfoundland and Labrador Ltd v St John’s Port Authority, 2011 FC 740 (54039 Newfoundland) ...

  [22]            Rule 81(1) must be considered in light of the Supreme Court’s acceptance of hearsay on a principled basis (see Ethier v Canada (Royal Canadian Mounted Police) (1995), 95 FTR 181, aff’d 66 ACWS (3d) 476 (CA)). ... CRA officials considered nine other cases where internal accounting or computer errors led to the overpayment of GST/PST ...

  [31]            The applicant further submits (i) that he has not committed any tax fraud, (ii) that he has financial difficulties that should be considered assessing his tax obligations, (iii) that he became indebted in order to pay his tax debt to the respondent and that he should consequently be reimbursed, (iv) that he received no guidance from the respondent in managing his tax affairs, and (v) that the respondent has impermissibly profited from his ignorance as a recent immigrant to this country ... [41]            The applicant’s request that his financial hardship be considered in addressing his obligation to pay his tax debts can be construed as a request for taxpayer relief ...

  [6]         Each head of relief sought will be considered in turn.   (1)        The request for application of the CRA’s fairness and remissions procedures. [7]         Mr. ... Zins’ tax obligation can not succeed because this issue was considered and rejected by the Tax Court.  ...

  [20] First, there is nothing to suggest any sleight of hand on the part of the Minister or his department with the objective of removing any documents that might be considered pertinent from his office before he signed his decision. ... When the federal board in question is a department, it cannot be considered that every document in that department is pertinent or was in the decision maker’s possession. ...

Baker Energy Resources Corp. and al (1988), 24 C.P.R. (3rd) 66, McNair J. provided a general, six-point review in which he defined the parameters for a question or document to be considered relevant in points 1 to 3, and then in points 4 to 6 provided a series of circumstances or exceptions under which exceptionally, ultimately, a question does not have to be answered or a document does not have to be produced. [15] The Court said the following in pages 70 to 72: 1.   ... The court should not compel answers to questions which, although they might be considered relevant, are not at all likely to advance in any way the questioning party's legal position: Canex Placer Ltd. v. ...

I note that the affidavit of Alexander Hoffman was not part of the material before the decision maker and therefore could not have been considered by him. ... I do not believe that this evidence constitutes “new evidence” and it should not be considered during this judicial review ...