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We would also emphasize that although the reasonable expectation of profit is a factor to be considered at this stage, it is not the only factor, nor is it conclusive.  ...

He considered that he did not own the condominium until the closing date. [20]          Unfortunately for Mr. ...

Lavallee was a “shared-custody parent” for the respective periods of July 2014 to June 2015, July 2015 to June 2016 and July 2016 to June 2017. [2]   Being considered a shared-custody parent, Ms. ...

He considered these payments to be spousal support payments and as such deductible under paragraph 60(b) of the Act. ...

The Queen, 2013 FCA 69, 2013 DTC 5061, (affirming 2012 TCC 291), the Federal Court of Appeal considered a similar set of facts. ...

In any event, even if the accountant's letter was received, it was still outside the 90-day limit for filing the notices of objection and contains no application for an extension of time or makes any reference to reasons for late filing at all, and hence, could not be considered an application for extension to the Minister in any event.   ...

He has continued to file T1135s annually since then as required. [9]   He was assessed a $2,500 penalty for not filing his 2015 form on a timely basis and that is the only issue in this appeal. [10]   The respondent put in by way of affidavit evidence blank copies of CRA’s 2015 tax return form and the portions of the Income Tax Guide for 2015 it considered relevant. [11]   The question asked of Canadians on their 2015 tax return that is relevant asks, Yes or No: “Did you own specified foreign property at any time in the year where the total cost was more than $100,000?”   ...

I accept that this was a reasonable belief held by the Appellant. [22]   Other factors I considered were as follows. ...

That is not considered payment in normal circumstances. This is also explained by Justice C. ...

Reconsideration [19]   Having considered the submissions made by both Parties, and having reconsidered my previous inclination, I have changed my mind. ...