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.), considered whether notices of reassessment under the ETA were not mailed to the correct mailing address in the context of an application for an extension of time to object to reassessments made under the ETA. ... My finding here is also based on my factual findings on the first issue considered earlier. [114] Recognizing that the ITA and ETA are separate statutes, it was reasonable here for the CRA, when mailing the notice of assessment under the ETA, to not use the appellant’s mailing address associated with her social insurance number for the purposes of the ITA. [115] Indeed, where a claimant applies for the GST/HST new housing rebates, it would raise a red flag if the application was made on the basis that the new house was purchased as the applicant’s (or a relation’s) primary place of residence, on the one hand, and then use a different mailing address in the application, on the other hand. ... Nonetheless, I can discern the substance of her statute-barred argument and have simply considered the applicable statutory scheme under the ETA. ...

., to be included in income,-- any amount (other than an amount referred to in paragraph 18(1)(m), paid or payable by the taxpayer, or a prescribed amount) that became receivable in the year by virtue of an obligation imposed by statute or a contractual obligation substituted for an obligation imposed by statute by (i) her Majesty in right of Canada or a province, (ii) an agent of Her Majesty in right of Canada or a province, or (iii) a corporation, commission or association that is controlled, directly or indirectly in any manner whatever, by Her Majesty in right of Canada or a province or by an agent of Her Majesty in right of Canada or a province As a royalty, tax (other than a tax or portion thereof that may reasonably be considered to be a municipal or school tax), lease rental or bonus or as an amount, however described, that may reasonably be regarded as being in lieu of any such amount, and that may reasonably be regarded as being in relation to (iv) the acquisition, development or ownership of a Canadian resource property or a property that would have been a Canadian resource property if it had been acquired after 1971, or (v) the production in Canada of (A) petroleum, natural gas or related hydrocarbons from a mineral resource or an oil or gas well, or (B) metal or minerals, to any stage that is not beyond the prime metal stage or its equivalent, from a mineral resource Situated on property in Canada in which the taxpayer had an interest with respect to which the obligation imposed by statute or the contractual obligation, as the case may be, applied;   Inducement, reimbursement, etc. (x) any particular amount (other than a prescribed amount) received by the taxpayer in the year, in the course of earning income from a business or property, from (i) a person or partnership (in this paragraph referred to as the “payer”) who pays the particular amount (A) in the course of earning income from a business or property, (B) in order to achieve a benefit or advantage for the payer or for persons with whom the payer does not deal at arm’s length, or (C) in circumstances where it is reasonable to conclude that the payer would not have paid the amount but for the receipt by the payer of amounts from a payer, government, municipality or public authority described in this subparagraph or in subparagraph (ii), or (ii) a government, municipality or other public authority, where the particular amount can reasonably be considered to have been received (iii) as an inducement, whether as a grant, subsidy, forgivable loan, deduction from tax, allowance or any other form of inducement, or (iv) as a refund, reimbursement, contribution or allowance or as assistance, whether as a grant, subsidy, forgivable loan, deduction from tax, allowance or any other form of assistance, in respect of (A) an amount included in, or deducted as, the cost of property, or (B) an outlay or expense, to the extent that the particular amount (v) was not otherwise included in computing the taxpayer’s income, or deducted in computing, for the purposes of this Act, any balance of undeducted outlays, expenses or other amounts, for the year or a preceding taxation year, (vi) except as provided by subsection 127(11.1), 127(11.5) or 127(11.6), does not reduce, for the purpose of an assessment made or that may be made under this Act, the cost or capital cost of the property or the amount of the outlay or expense, as the case may be, (vii) does not reduce, under subsection 12(2.2) or 13(7.4) or paragraph 53(2)(s), the cost or capital cost of the property or the amount of the outlay or expense, as the case may be, and (viii) may not reasonably be considered to be a payment made in respect of the acquisition by the payer or the public authority of an interest in the taxpayer or the taxpayer’s business or property;     General limitations   18. (1) In computing the income of a taxpayer from a business or property no deduction shall be made in respect of   […]   (m) Royalties, etc. – any amount (other than a prescribed amount) paid or payable by virtue of an obligation imposed by statute or a contractual obligation substituted for an obligation imposed by statute to (i) Her Majesty in right of Canada or a province, (ii) an agent of Her Majesty in right of Canada or a province, or (iii) a corporation, commission or association that is controlled, directly or indirectly in any manner whatever, by Her Majesty in right of Canada or a province or by an agent of Her Majesty in right of Canada or a province As a royalty, tax (other than a tax or portion thereof that may reasonably be considered to be a municipal or school tax), lease rental or bonus of as an amount, however described, that may reasonably be regarded as being in lieu of any such amount, and that may reasonably be regarded as being in relation to (iv) the acquisition, development or ownership of a Canadian resource property or a property that would have been a Canadian resource property if it had been acquired after 1971, or (v) the production in Canada of (A) petroleum, natural gas or related hydrocarbons from a mineral resource in Canada or an oil or gas well in Canada, or (B) metal or minerals, to any stage that is not beyond the prime metal stage or its equivalent, from a mineral resource in Canada. ...

The learned judge concludes at paragraphs 49 and 50: The limits on solicitor-client privilege, in relation to non-legal professionals, has been considered.    ... No. 25, the Supreme Court of Canada considered the constitutionality of the predecessor to subsection 231.2(3) and distinguished the investigation of criminal conduct from the enforcement of compliance with the ITA. ... Rivet knew that Welton Parent or its principals considered all the documentation and information in their files privileged. ...

The version of events given by Julien Carignan, a senior manager of an organization that received gifts, will be considered at some length. ... The search was part of an investigation into what Revenue Canada considered a tax scheme. ... He also considered that the prices suggested in the Guide Vallée are real prices for gallery sales and need not be checked. ...

Competent authority agreements are not considered precedents for either the taxpayer or the CRA in regard to (re)assessments relating to subsequent years or for competent authority negotiations on the same issues. ... A taxpayer cannot accept the terms of an agreement for only some issues or taxation years involved, since the original request by the taxpayer would have asked for assistance in respect of all issues and taxation years involved and the competent authorities would have considered all issues and years in the negotiations. 55. ... Subbiah’s statements can be considered an admission and therefore an exception to the hearsay rule: see, generally, paragraphs 6.408 to 6.416 of Sopinka, Lederman & Bryant: The Law of Evidence in Canada, 4th ed. by Sidney N. ...

It is not established that O’Donnell 2004 was considered to be part of common general knowledge. ... The article did suggest that they should be considered “active hormonal agents for prostate cancer.” ... This was not considered to be a significant suppression of cortisol and therefore was not a major concern. ...

The question of what is fair market value for inventory purposes was considered in Sellers-Gough Fur Co. ... He considered putting it into the company safe, but discarded that idea because the company had only a light safe and no burglar alarm protection. ... The subjective statements of intention by the plaintiffs must be considered along with objective facts. ...

The search was part of an investigation into what Revenue Canada considered a tax scheme. ... He also considered that the prices suggested in the Guide Vallée are real prices for gallery sales and need not be checked. ... The concept of fair market value has been considered by the courts, inter alia in Henderson v. ...

In the context of other provisions of the Act, including subsection 169(1), the courts have considered on a number of occasions whether an input was made “in the course of” a “commercial activity”. ... The Supreme Court of Canada stated that: [50] … [c]ontractual interpretation involves issues of mixed fact and law as it is an exercise in which the principles of contractual interpretation are applied to the words of the written contract, considered in light of the factual matrix of the contract. [36] The Supreme Court of Canada also turned its attention to the role and the nature of the surrounding circumstances in contractual interpretation and the nature of the evidence considered: [57] While the surrounding circumstances will be considered in interpreting the terms of a contract, they must never be allowed to overwhelm the words of that agreement (Hayes Forest Services, at para. 14; and Hall, at p. 30). ... I surmise that PC Bank considered that the cost and efficiency savings attributable to the outsourcing of services to FDR and then to TSYS was of greater value than the GST that PC Bank self‑assessed on the TSYS supply. [156] Ms. ...

Winding-up was not in contemplation and cannot be considered as probable in the case of this old and well-established company. ... (a), (d) or (g) affect duty on the restricted shares can be better considered after the general discussion of principles. ... There are two lots of the ordinary shares in these private companies to be considered; those which were actually held by the late G. ...