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For example: a.when collection has been suspended due to an inability to pay and substantial interest applies to the outstanding amount b.when a taxpayer's demonstrated ability to pay requires an extended payment arrangement, consideration may be given to cancelling all or part of the interest for the period from when payments start until the amounts owing are paid, as long as the agreed payments are made on time and compliance with the act is maintained c.when payment of the accumulated interest would cause a prolonged inability to provide basic necessities (financial hardship) such as food, medical care, transportation, or accommodation d.when a taxpayer cannot make a reasonable payment arrangement because the interest charges would absorb a significant portion of the payments, cancelling all or part of the interest for the period from when payments start until the amounts owing are paid may be considered, as long as the agreed payments are made on time and compliance with the act is maintained Incapacité de payer ou difficultés financières ¶ 27. ... Where circumstances beyond a taxpayer's control, actions of the CRA, inability to pay, or financial hardship has prevented the taxpayer from complying with the act, the following factors will be considered when determining if the minister's delegate will cancel or waive penalties and interest: a.whether the taxpayer has a history of compliance with tax obligations b.whether the taxpayer has knowingly allowed a balance to exist on which arrears interest has accrued c. whether the taxpayer has exercised a reasonable amount of care and has not been negligent or careless in conducting their affairs under the self-assessment system d.whether the taxpayer has acted quickly to remedy any delay or omission Facteurs de décision ¶ 33. ...

Ghazi, she advised him, in a letter dated January 29, 2018, of a proposed GST/HST adjustment of over $650,000 plus penalties that he would have to pay as a result of being considered a builder in the sale of two real estate properties located in the Toronto region. ... The Applicant relies on JP Morgan and Ereiser for the proposition that the Federal Court retains jurisdiction in these matters. [20]   In fact, the parties agree that if the circumstances of the notice of application fall within the jurisdiction of the Tax Court, then the application would be barred from being considered by this Court. ...

The only mode of infringement alleged or addressed in these reasons was infringement by inducement. [31]   It is also noteworthy that Courts in Canada have in the past considered and construed claims drafted as “composition for use in the treatment of (…)”, or “Swiss-type claims”, for the purpose of determining their validity in light of the jurisprudential prohibition against patenting claims for methods of medical treatment (see Hospira Healthcare Corporation v Kennedy Trust for Rheumatology Research, 2018 FC 259 and cases cited at paragraph 143 of that decision). ... The Court is not satisfied that it is plain and obvious that the act of engaging in infringing conduct, if established in that particular context, cannot arguably be considered the “something more” that is required to give rise to punitive damages. ...

The OPC has already recognized in its 2016 Consultation Paper that it faces a challenging balancing of rights: As for the “right to be forgotten” debate, if such a mechanism were to be considered in Canada, there would need to be a careful balancing with other societal values, such as the right to freedom of expression, which is guaranteed under the Canadian Charter of Rights and Freedoms. [69]   Google claims that the mere application of PIPEDA to a search engine is enough to breach its right to free speech because, among other things, Part 1 of PIPEDA would force Google to obtain a person’s consent to the collection, use or disclosure of personal information. [70]   If Google challenges the constitutionality of certain provisions of Part 1 of PIPEDA, it would have to explain how those provisions infringe its right to free speech. ... Nor is there any error in leaving the door open to the judge hearing the application to decide, after having considered the evidence that will be filed, that he or she should decline to answer the reference questions. ...

Because of the two-year limitation period, only the Fuel sold from February 8, 2011 to January 31, 2013 was considered.   ... According to Highlands, the Minister’s interpretation would also be contrary to the Federal Court of Appeal’s decision in The Queen v Stevenson Construction Co Ltd (1978), 24 NR 390 (FCA) [Stevenson], which considered section 44(2) of the ETA, the predecessor to section 68.19 of the ETA.   ...

These militias are controlling area [sic] that are only 500m far from our home and they are considered a real threat to Christians [sic] reside in Damascus. ... It is “boilerplate” language that fails to say anything intelligible. [43]   The further difficulty is that the decision letters are framed in such a way as to leave the impression that the applications were considered on their merits. ...

After reviewing the RAD’s decision, I conclude that it carefully considered the translation issues raised by the applicants. ... It gave clear and well-developed reasons demonstrating that it considered all of the evidence and allegations. ...

In my view, as long as the MD did not purely consider past work, but also considered future work, then he acted within his jurisdiction. ... Having so considered the contents of the various affidavits, I do not find that there was a reasonable apprehension of bias: an informed (i.e. reasonable) person, viewing the situation realistically and practically and having thought the matter through, would not conclude that it is more likely than not that the MD would have been unable to decide the case fairly (Committee for Justice and Liberty v National Energy Board, [1978] 1 S.C.R. 369). [42]   The threshold for bias, whether real or perceived, is high. ...

However, since this issue of whether 70% of the ADI is unsafe was not raised in the NOO and was not mentioned in the Pilote Affidavit or the Respondent’s Memorandum of Argument, it was not properly before me and will not be considered. ... It reads: If toxicity data indicate no prenatal or postnatal toxicity or the level of concern is low (and the data is considered complete), then the presumption for use of the 10-fold PCPA factor will be obviated with respect to the potential for prenatal and postnatal toxicity (i.e. the PCPA factor would be reduced to one-fold). ...

I concur that this is appropriate and accordingly find that expert fees should be capped at the amount charged by senior counsel for similar time involvement. [41] I accept the merits of this approach in cases where there is need to place a limit on expert fees charged at what could be considered excessive hourly rates. ... In Bell, the Court considered it fair to employ the actual commercial rate prevailing at the relevant time, and it ultimately relied on the prime bank lending rate (at 717-718). [59] The Plaintiffs submit that the prime bank lending rate does not reflect the rate at which banks actually lend money in normal commercial circumstances and that unsecured loans would likely involve rates of 1-2% above the prime rate, i.e. in the range of the 5% claimed. ...