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The policy document explains that when assessing a self-employed client for eligibility, it is not so much the profitability of the business that is important, but how the profitability, considered together with productivity and performance, reflects a client’s regular capacity for work.   ... The February 2005 initial adjudication summary shows that the Medical Adjudicator reviewed and considered all medical and non-medical evidence in support of Mr. ... Wodak’s statement in his letter of May 21, 2015, that the medical adjudicator “did not comment on the T5007 information slips,” social assistance benefits are not considered earned income and would therefore not be considered by the adjudicator when evaluating earnings. ...

If the plaintiffs had purchased the book debts of, say, a fashion store, in one isolated transaction, where they had no knowledge of the clothing business and no means within their command to enhance the book debt value, then the transaction might very well be considered to be entirely outside their “business”. ... It may be that, it he had directed his mind to the matter, he would have considered that, if profits were made, and a distribution was contemplated, then repayment of the debt in whole or part would be preferable to the declaration of dividends. ... Therefore even though it was an isolated transaction and he is certainly not in the business of acquiring loans or book debts, the acquisition of them cannot he considered as a capital investment by him. ...

I do not agree with counsel for the plaintiff that all these words are to be used disjunctively nor can I consider that the cutting of aluminum foil into shorter lengths can be considered as giving new form to the foil. ... Because of my finding that the plaintiff has neither changed the form, the qualities nor the properties of the material, it is perhaps not necessary for me to determine whether the words in that expression are to be considered disjunctively or conjunctively. I wish, nevertheless, to state that, in my view, they should be considered conjunctively: they are all applicable in all of the cases which were referred to me and which I was able to discover, where it has been held that the taxpayer was either manufacturing or producing something within the meaning of the Excise Tax Act, RSC 1970, c E-13. ...

It was a business transaction made in the ordinary course of the business of appellant companies of lending money, and Mr Elman evidently considered that, with the security offered, the profit to be anticipated justified the risk. ... In the Tax Appeal Board case of Douglas Casey v MNR, 25 Tax ABC 49, appellant had accepted a piece of vacant land which he considered at the time to be worth about $300 in satisfaction of a debt of $600 which he was having difficulty collecting. ... To say that only this bonus together with the interest earned on the loan should be taxable and the excess considered as capital gain is equivalent to finding that the property was acquired as an investment, which it was not. ...

The Officer stated: “[a] lack of knowledge of taxation rules cannot be considered beyond a taxpayer’s control as information is readily available on our website and through our General Enquiries telephone line”. [12] The letter provided additional information, noting that “depending on the type of investment in your TFSA, you can generally withdraw any amount from the TFSA at any time. ... Afshar’s lack of knowledge of the rules could not be considered beyond her control because information and resources were publicly available through the CRA website and General Enquiries telephone line; ● Ms. Afshar was advised via the NOA on July 20, 2021 of her excess contributions but the excess contribution remained in her account until 2022, and as such, she was considered to not have taken action within a reasonable time frame; ● The investment losses she incurred within her TFSA were not considered a “withdrawal” and did not create TFSA contribution room; and ● Given the information on Ms. ...

The officer found that 26 of the 94 articles could be considered original news content, and that AJS appeared to be engaged in the production of original news content so as to satisfy subparagraph 248(1)(a)(v) of the ITA. [9] The CRA then sent AJS’s application to the Advisory Board, as it was required to do before making a final decision. ... The Minister acknowledged that neither the legislation nor the Guidance sets a threshold amount, and relied on the CRA’s interpretation that an organization is considered to be engaged in the production of original news content if it demonstrates a commitment to producing original news content on an ongoing basis. ... The Minister reasonably considered the legislative framework and AJS’s submissions, and made a decision that was justified in relation to the facts and law. ...

"The reviewing court must refrain from reweighing and reassessing the evidence considered by the decision maker" (Vavilov at para 125). ... In March 2020, their business was completely shut down due to government restrictions as their business was in beauty industry and it was [sic] considered as essential business. ... From the record, the Second Reviewer applied the eligibility criteria and considered the entire evidentiary record in determining that the Applicant was not eligible for the CRB. ...

I indicated from the Bench that I considered the McGrath decision to be a proper interpretation of the law applicable to the taxation years in dispute in this action, and that accordingly this action must be dismissed. ...

As per detailed information in respect of the activities of the Applicant and scheduled departure with ample time for preparations on his behalf, the Applicant now presents an “eleventh hour” application for a stay of removal, an exceptional remedy, an injunction which is only considered by the Court, if the conduct of such person is beyond reproach (Antonucci v Canada (Minister of Citizenship and Immigration), [1996] FCJ No 1320). ...

In short, we think that he carefully considered the nature and substance of the transaction which the applicable jurisprudence requires him to do. ...