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In Revenue Canada's view, examination fees paid to the Medical Council of Canada and the Educational Commission for Foreign Medical Graduates are not considered tuition fees. ... From a Technical Interpretation, Business and General Division, issued December 19, 1991, Revenue Canada is of the opinion that a student is considered to be enrolled in an educational institution if the student is registered with the registrar of the institution such that the student is contractually liable for any tuition fees required to be paid to the institution with respect to the chosen course of study. ...

Abstinence from all products containing gluten must be strictly and completely observed as a result of a physical impairment of the intestine which is considered extremely serious. ... Analysis [9] To be entitled to the credit for mental or physical impairment, a taxpayer must meet the conditions set out in subsection 118.3(1), which are as follows: (a) an individual has a severe and prolonged mental or physical impairment, (a.1) the effects of the impairment are such that the individual's ability to perform a basic activity of daily living is markedly restricted, (a.2) in the case of (i) a sight impairment, a medical doctor or an optometrist, (ii) a hearing impairment, a medical doctor or an audiologist, (iii) an impairment not referred to in subparagraph (i) or (ii), a medical doctor, has certified in prescribed form that the impairment is a severe and prolonged mental or physical impairment the effects of which are such that the individual's ability to perform a basic activity of daily living is markedly restricted, (b) the individual has filed for a taxation year with the Minister the certificate described in paragraph (a.2), and (c) no amount in respect of remuneration for an attendant or care in a nursing home, in respect of the individual, is included in calculating a deduction under section 118.2 (otherwise than because of paragraph 118.2(2)(b.1)) for the year by the individual or by any other person.... [10] A severe and prolonged impairment is defined in subsection 118.4(1) as follows: (1) For the purposes of subsection 6(16), sections 118.2 and 118.3 and this subsection, (a) an impairment is prolonged where it has lasted, or can reasonably be expected to last, for a continuous period of at least 12 months; (b) an individual's ability to perform a basic activity of daily living is markedly restricted only where all or substantially all of the time, even with therapy and the use of appropriate devices and medication, the individual is blind or is unable (or requires an inordinate amount of time) to perform a basic activity of daily living; (c) a basic activity of daily living in relation to an individual means (i) perceiving, thinking and remembering, (ii) feeding and dressing oneself, (iii) speaking so as to be understood, in a quiet setting, by another person familiar with the individual, (iv) hearing so as to understand, in a quiet setting, another person familiar with the individual, (v) eliminating (bowel or bladder functions), or (vi) walking; and (d) for greater certainty, no other activity, including working, housekeeping or a social or recreational activity, shall be considered as a basic activity of daily living. [11] It is clear from Dr. ...

However, if the Minister's conclusion was based on an erroneous principle of law, if the Minister failed to take into account all the relevant circumstances of the employment, considered irrelevant factors, acted arbitrarily or failed to observe a principle of natural justice, or if the discretion was exercised by a person who did not have authority to do so, the Court may intervene, reverse the decision and itself make the decision the Minister should have made. [5] Annette LeBlanc stated the following in the Notice of Appeal: I, Annette LeBlanc, am the major shareholder of the company and I manage the affairs or business of the company. ... As a result the employment was considered to be excepted/excluded employment and was not insurable for purposes of the Unemployment and Employment Insurance Acts. [11] Mr. ...

Mulvale said that he considered the first three to be most comparable, and he gave the opinion that the appropriate value per acre for the subject property at November 30, 1990 was $25,000. ... Sabourin viewed this as a rate of decline of 24.66% per year, and he considered the annual rate of decline of the three residential properties to be respectively, 6.63%, 9.95% and 6.82%. ...

In order for the RV to not be considered a "leasing property" according to subsections 1100(17) and (17.2) of the Regulations, the appellants must have established, on a balance of probabilities based on the evidence presented at trial, that they were carrying on a business with a reasonable expectation of profit and that they were actively involved in that business on a continuous basis. ... Revenue derived from the right of a person or partnership (except the owner) to use or occupy the property, and revenue from services offered that are ancillary to such use or occupation, are considered to be rent. ...

Bennett that the Appellant's responsibilities involved much more than in-class teaching. [7] At the hearing of the appeal the Appellant produced detailed breakdowns of the number of hours which he spent in carrying out what he considered to be the duties of his employment. ... The course taught by the Appellant was considered on that basis to have a value of.33 of a full-time course. ...

The Minister instead considered the eligible portion of the loss — $3,456 for Yves Bilodeau, $4,219 for Luc Brassard, $4,157 for Serge Martel and $7,560 for Gaston Tremblay — to be a capital loss. [2] The losses were incurred by each of the appellants when they were members of the Coopérative de travailleurs du Royaume (“the Coop”). ... What matters is that, between the two of them, they owned a majority of Chambord’s shares giving them the voting power to elect a majority of the directors. [20] In my opinion, the law is sufficiently clear to conclude that Chambord was controlled by two public corporations and therefore could not be considered a private corporation within the meaning of the Act. ...

Consequently, a number of facts and elements should be considered in discounting the value of testimony. [39] In this case, I am convinced on the balance of evidence that I should attach no value to the appellant's testimony. ... I refer to the Notice of Appeal for the 1995 taxation year dated October 2, 1998, the last paragraph of which reads as follows: [TRANSLATION] I agree that additional income of $3,555 should be considered for 1995. [41] The appellant may not have had an obligation to have careful, detailed and exemplary accounting records in his possession. ...

I am allowing a deduction in the amount of $582.00 in computing the Appellant's income for the years to which it can reasonably be considered to relate. ... The remaining $582.00 is a prepaid expense for three years of air time purchased as a package in 1993 and are deductible in the years in which the expense can reasonably be considered to relate. ...

Arm's length (1) For the purposes of this Act, (a) related persons shall be deemed not to deal with each other at arm's length; and (b) it is a question of fact whether persons not related to each other were at a particular time dealing with each other at arm's length. [13]          When we analyze the concept of arm's length as it is found in the Act, it is clear that persons who are related by blood constitute related persons for the purposes of the Act and are considered not to be dealing with each other at arm's length. ... He was therefore not related to Micropath. [14]          What is surprising in the Gosselin decision (supra) is that two shareholders each holding 50% of a company and not related to each other were considered not to be dealing at arm's length with that company. ...