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The defendant suggests as well that the words of the section be given their ordinary grammatical meaning, that they be considered in the light of the intent of Parliament, and be given an interpretation that allows for ease of application. ... At one time, the strict interpretation of revenue statutes was justified on the basis that revenue statutes were considered to have no other governing object other than the collection of taxes: Lord Halsbury, in Tennant v. ...

Defendant's Argument In contrast, the defendant's submission is that the plaintiff's payout to the employee cannot be considered remuneration. ... Counsel for the defendant has submitted that the employer contribution to the purchase of shares cannot be considered remuneration since the employees have not performed any additional service for the benefit of this program. ...

As I understand the teaching profession, positions in the Board Office are considered to be promotions over positions in the schools. ... They are to be considered conjunctively not disjunctively. In the Morrissey case, supra, it was held that, despite extensive time and effort spent by the taxpayer on the farming operation, its profitability was improbable and therefore the Moldowan test had not been satisfied. ...

Preliminary Issue: New Evidence [19] The Respondent argues that the Applicant has included materials in her Application Record that were not before the decision-maker, that this evidence is therefore improperly before the Court on judicial review, and that it should not be considered. [20] The general rule is that the evidentiary record before a court on judicial review is restricted to that which was before the tribunal (Association of Universities and Colleges of Canada v Canadian Copyright Licensing Agency (Access Copyright), 2012 FCA 22 at para 19). ... Reasonableness of the Decisions [28] The Applicant’s primary position on the reasonableness of the Decisions is that the income that had been reported in Box 28 of her 2019 T4A should be considered as contributing to the required $5,000 for CERB and CRB eligibility. ...

However, I find that none of these exceptions apply to the disputed documents here and accordingly, I have not considered them in reaching my decision. ... The Applicant was given numerous opportunities over that 18-month period to submit documents and information to remedy the issues identified with her applications, which documents and information the Officer considered [see Flock v Canada (Attorney General), 2022 FC 305 at paras 25-26]. [35] Having reviewed the record, I am satisfied that the Applicant was aware of the case to meet and given a full and fair opportunity to respond. ...

In the absence of an at-large extension of time, then, each request must be considered on its own merits. ... I see no reviewable error in this observation, as ignorance of the law is not generally considered a sufficient basis to extend a deadline under paragraph 256(3)(b) of the Excise Tax Act. ...

The CRA treated these submissions as a request for a second review of his eligibility for the CERB and the CRB. [8] As part of their review, the Officer considered various documents and information, including prior entries made by other CRA officers on its computer systems, the Applicant’s prior submissions, information gathered during telephone calls with the Applicant, and the Applicant’s income and deductions from income for the 2019, 2020, and 2021 taxation years. [9] While the Applicant had earned over $5,000 of gross self-employment income in the 2019 and 2020 taxation years, he suffered net losses. ... I have therefore not considered the Applicant’s arguments as they relate to the CERB decision. ...

The letter also specifically states that “If you are not a GST/HST registrant with a business activity involving real property transactions, and you are involved in one real property transaction, you have to report the tax you are considered to have collected on form GST 62, Goods and Services Tax/Harmonized Sales Tax (GST/HST) Return (non-personalized).” [12] Mr. ... Gerlings was deemed, by the CRA, to be a builder of a house and considered to have made a taxable self-supply on the date of transfer to his mother. ...

Both the outcome of the decision and its reasoning process must be considered in assessing whether these hallmarks are met (Vavilov at paras 15, 95, 136). [21] Such a review must include a rigorous evaluation of administrative decisions. ... Indeed, the appeal was doomed to fail for two reasons: (i) the Appeal Division properly considered and rejected Mr. ...

A notice or other communication is considered to be made available if it is posted by the Minister in the individual’s secure electronic account and the individual has authorized that notices or other communications may be made available in this manner and has not before that date revoked that authorization in a manner specified by the Minister. ... As such, counsel was not in a position to provide any submissions in response to the Court’s inquiries. [29] In my view, this inconsistency in the evidentiary record before the Officer, combined with the absence of any analysis in the Decision that addresses the inconsistency or, indeed, identifies at all the evidence underlying the conclusion that the 2021 NOA was sent to the Applicant electronically in July 2022, necessarily undermines the reasonableness of the Decision. [30] In so concluding, I have considered the Respondent’s submission that the Decision Letter notes not only that the Applicant’s overcontribution to her TFSA was not removed in 2022 but also that her TFSA remained in excess throughout 2023. ...