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Batalha claims that he was not only a subcontractor, but that, in the case of three other clients, he considered himself a business partner of the appellant's, and that their agreement was to share the gross fees received equally. ...

The tax advantage which is received from gifts is not normally considered a “benefit” within this definition, for to do so would render the charitable donations deductions unavailable to many donors ...

Miller J. considered whether shares created and distributed under Mexican law were a dividend. ...

A letter of June 3, 2010 from the Canada Revenue Agency (CRA) to the Appellant, stated:   After conducting a complete and impartial review of all of the information relation to the appeal, it has been determined that Heva Ng received employer controlled tips in the amount of $11,461.00; therefore, these tips are considered insurable employment.   ...

He made instalments of $2,980.84 [7], a figure which ought to be considered by the Minister in reassessing. ...

  [11]          Each of these items is considered separately below.     [12]          Before doing so, I would first make a general comment about the appellant’s testimony. ...

So there is no basis in our submission for any accrual analysis to be considered.   ...

The actions of the father and his son must be considered separately since the penalty is applied to punish the negligent actions of the taxpayer, specifically the failure to declare income for two years. ...

How the cheques were cashed   [11]          The relevant assumptions, as reproduced below, are set out in paragraph 6 of the Reply to the Notice of Appeal:   [Translation]   (y) the time the appellant waited before cashing his paycheques varied from 23 to 68 days in 2006 and from 3 to 56 days in 2007, but it was impossible to determine the times for 2008 and 2009;   (z) the appellant considered those times to be reasonable, since the payor did not have the money to pay him and his personal line of credit was less costly than the payor’s;   (aa) the payor’s other employees did not wait before cashing their paycheques;   [12]          The appellant admitted that he varied when he cashed his paycheques, as shown. ...

I have considered the following:   a)      The result of the proceeding:   All appeals were allowed in part. ...