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Hrga was considered to be funds or property that was appropriated to a taxpayer in those years and which, by virtue of paragraph 15(1)(b) of the Income Tax Act, should have been included in computing his income. ... In Toma, the taxpayer personally looked after a situation where his companies were in peril and, once produce from his business had been delivered to Allstate, he considered the matter to be closed and forgot about it. ...

In 2005, they founded B&P together; [4] WHEREAS from the early 1980s until the file was transferred to the firm Smart & Biggar in late 1994, Maître Brouillette was ultimately responsible for preparation, filing and proceedings concerning the application filed on February 8, 1990, leading to registration ’683 issued on July 7, 1999; [5] WHEREAS the Court is satisfied it can be reasonably considered that registration ’683 was obtained to protect an important intellectual property asset of Bauer and that multiple discussions and consultations took place between Maître Brouillette and Bauer management concerning the decision to proceed with said registration; [6] WHEREAS the Court is satisfied that it can be reasonably considered that Maître Brouillette was aware of the various strengths and weaknesses of registration ’683, including any potential issues with regard to chain of title; [7] WHEREAS the evidence concerning the past representation of Bauer (both general and specific to registration ’683) by Maître Brouillette and the importance of this representation are to be viewed as not effectively contested by Therma Blade in that the latter did not cross-examine any of Bauer’s affiants; [8] WHEREAS in this regard, and in the absence of cross-examination, the Court cannot accept the argument that the information held by Maître Brouillette should be deemed irrelevant in light of the fact that Maître Brouillette’s involvement was some years ago and that over time, the management of Bauer and its predecessors has undergone certain changes; [9] WHEREAS counsel for Therma Blade chose not to produce any evidence to establish any measures that may have been taken to prevent the disclosure and/or use, whether voluntary or other, of confidential information concerning Bauer’s affairs against its interests in the context of this litigation; [10] WHEREAS in determining whether B&P should be disqualified from representing Therma Blade, the two (2)-part test developed by the Supreme Court of Canada in MacDonald Estate v. ...

[6]                CONSIDERING with regard to issue A), which involves in this context examining the nature of a garnishment before judgment, the Court is of the view that, contrary to the third parties’ claims, the escrow agreements (the agreements) cannot be considered to have transferred outside the judgment debtor’s patrimony and in favour of the garnishees (the notaries) any amount that could be owing to the judgment debtor following the sale of the immovables in question; [7]                CONSIDERING the Court is of the view, as submitted by Her Majesty at paragraph 18 of her submissions of March 18, 2011, that [TRANSLATION] “a garnishment before judgment is a conservatory measure that protects an eventual right to any claim. ... As for Her Majesty, it must be noted that she is to be considered here as a creditor with an enforceable judgment that she is enforcing through a garnishment after judgment and that the agreements cannot then block the garnishment after judgment she is making. ...

However, when the decision is considered as a whole, I am satisfied that the Officer had due regard for Sebastian’s best interests, explaining in an intelligible fashion why they did not outweigh other factors in the case. ...   [15]            The Officer specifically considered the letter provided by Ms. ...

The Minister’s Delegate considered all of the arguments that had been put forward by Ms. ... On the consent of the parties, the style of cause will be amended to replace the “Canada Revenue Agency” as the respondent with the “Attorney General of Canada”. [14]            I have considered the issue of costs. ...

The applicants allege that they considered settling in Armenia, but decided against it given that they have never lived there and have no family who they could count on there. ... That said, in its analysis, the RAD considered various reliable information sources that supported its finding that the applicants do not fit the profile of at-risk individuals, as their fear of not receiving adequate health care is shared by the general population of Armenia. [10]            The applicants’ refugee protection claim, which is based on sections 96 and 97 of the IRPA, is not a request for an exemption under section 25 of the IRPA from having to apply for a permanent resident visa from outside Canada. ...

Biswal regarding the penalties and interest at issue here, it would be assessed and considered by CRA, and it would not take the position that the request was res judicata, having already been considered.  ...

The RPD considered the Applicant to be excluded from refugee protection in Canada on the basis of Article 1 F (b) of the Convention. [5]   Upon appeal to the RAD, the Applicant requested an oral hearing. ... He also submits that the RAD erred by shifting the burden from the Minister of Citizenship and Immigration (the “Respondent”), to show why the exclusion should apply, to him, to show why it should not apply. [9]   The Respondent argues that the arguments raised by the Applicant in this application were not presented to the RAD and cannot now be raised before the Court upon the application for judicial review. [10]   Further, the Respondent argues that the RAD did conduct its own analysis and reasonably found that the exclusion finding was reasonable. [11]   The first matter to be considered is the standard of review. [12]   For any issue of procedural fairness, the standard of correctness will apply; see the decision in Canada (Citizenship and Immigration) v. ...

That decision dealt with an insurance agent who set aside, as a reserve, amounts which had been received as premiums under policies which the agent considered not to have yet been earned. ... I have considered one other aspect of the wording of subsection 32(1) and that is the wording which states that an insurance agent "may deduct as a reserve in respect of unearned commission an amount.... ...

The Deputy Minister of National Revenue for Customs and Excise or such other person as the Minister of National Revenue could have designated had not, as of the date of the hearing in the present case, considered and weighed the circumstances of the case and reported his opinion and recommendation thereon to the Minister as contemplated by section 162 of the Customs Act; furthermore, the Minister of National Revenue had not yet given his decision or referred the matter to court as contemplated by section 163 of the Customs Act. ... I have concluded that the wisest course to follow here is to refrain from intervening at this time and to allow the difficult and basic question of constitutionality and Charter transgression to be fully considered at the trial of this action, where declaratory relief can be given. ...