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On January 18, 2022, the Minister considered the December 10, 2021 purported electronic Notice of Objection and informed the Appellant that the objection could not be accepted, pursuant to subsection 165(1) of the Income Tax Act, as it was not filed within 90 days from the date of the reassessments. ...

I wouldn’t have ever considered the investment were it not for the charities. ... The rate on 20-year provincial bonds, which he considered to be a very safe investment, was in the range of 4.5% to 4.7%. The rate on 20-year Canadian corporate bonds, which he considered to be a riskier investment, was 5.3%. [243] [183]      Mr.  ...

  [10]         The cross-examination of the auditor did not reveal any anomaly, irregularity or abuse whatsoever in the analysis of the data considered in making the assessments. ... The onus on the Minister will be greater if the taxpayer presents plausible explanations showing a non-taxable source of this additional income.   78      The Minister's burden of proof was considered in J. ...   [45]         The appellants did not in any way challenge the value added to their assets except to submit that the purchase of the licences should have been considered a current expense incurred for the purpose of earning income. ...

I have not even considered the amount of time he spends travelling with the team on away games. ...   [32]     Appellant’s counsel also dealt with the other factors required to be considered in determining the status of a worker ...   [41]     Notwithstanding the weight given to my determination that the Appellant did not carry on a business, I will make further comment, largely by way of summary, on the other factors to be considered. ...

Following a transaction consisting of the sale of a property by the appellant to a corporation in which he holds the majority of the shares, an amount of $523,775 was added to the appellant's income, and this amount is considered by the Minister to be a benefit conferred on a shareholder according to subsection 15(1) of the Income Tax Act ("the Act"). ... Fibers as a special purchaser, which justifies the fact that it paid a price that corresponds to a suitability value and eliminates any cash benefit the appellant may have been considered to have received. [13]     In the cross-examination, Mr. ... Fibers could have considered because, in actual fact, those options had not been considered before deciding to purchase the property. ...

It must also be emphasized that section 67 does not refer to related persons, even though the fact that related persons were involved in this matter was one of the factors that the Minister’s auditor considered in applying that section ... The issue of inconsistent assessments was considered by the Federal Court of Appeal in Hawkes v. ... H.M., this Court considered earlier jurisprudence and confirmed the basic principle that it is the duty of the Minister to assess, and if necessary reassess, taxpayers’ returns so as to apply correctly the law to the facts. ...

Flora was considered to be insolvent by its directors in November 2006.   17.    ... A future event may therefore be considered if it is probable that it will occur and make the debt collectible. [3]   [15]         It seems important to note that it is unnecessary for the creditor to exhaust all possible measures of collection. ...

Why should monies put indirectly into the “project” not be considered part of that adventure, given that had they been put in directly they would be considered part of the adventure; or put another way, why should the introduction of an intermediary affect the nature of the monies from being on income account to being on capital account? ... As stated in Freud:   It is, of course, obvious that a loan made by a person who is not in the business of lending money is ordinarily to be considered as an investment. It is only under quite exceptional or unusual circumstances that such an operation should be considered as a speculation ...

They considered divorce. As Mr. Passarello put it, his world was collapsing. [11]     Mr. ... And I do believe the Passarellos testimony, but I also find it is necessary to look at the surrounding circumstances and to those who actually devised the arrangement, especially, as here, where the evidence is that the Passarellos relied entirely on their professional advisor for tax planning advice. [22]     Respondent's counsel gleaned from the many cases dealing with this issue a number of circumstances that I should consider in ascertaining whether it "may reasonably be considered that one of the main reasons" is the reduction of tax. ... However, in that case there was some testimony to the effect that tax had been expressly considered, giving rise to the possibility that tax reduction was a main purpose. ...

The Queen, [1982] C.T.C. 214; 82 D.T.C. 6179. 4.03 Analysis 4.03.1 The respondent's position is based primarily on the view that, on issues of corporate control, it is de jure control that must be considered rather than de facto control. ... The technical notes published by the Minister on September 13, 1988, with respect to this amendment read as follows: New paragraph (1.2)(b) provides that a corporation can be considered to be controlled by a person or particular group of persons notwithstanding that the corporation is also controlled by another person or group of persons. As a consequence, under this paragraph, a corporation can be considered to be controlled at the same time by several persons or group of persons. ...