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  [11]          Subsection 247(2) says:    247(2) Where a taxpayer. . . and a non-resident person with whom the taxpayer. . . does not deal at arm’s length. . . are participants in a transaction or a series of transactions and   (a)  the terms or conditions made or imposed, in respect of the transaction or series, between any of the participants in the transaction or series differ from those that would have been made between persons dealing at arm’s length, or   (b)  the transaction or series   (i)    would not have been entered into between persons dealing at arm’s length, and   (ii)    can reasonably be considered not to have been entered into primarily for bona fide purposes other than to obtain a tax benefit,   any amounts that, but for this section and section 245, would be determined for the purposes of this Act in respect of the taxpayer. . . for a taxation year or fiscal period shall be adjusted (in this section referred to as an “adjustment”) to the quantum or nature of the amounts that would have been determined if,   (c)  where only paragraph 247(2)(a) applies, the terms and conditions made or imposed, in respect of the transaction or series, between the participants in the transaction or series had been those that would have been made between persons dealing at arm’s length, or   (d)  where paragraph 247(2)(b) applies, the transaction or series entered into between the participants had been the transaction or series that would have been entered into between persons dealing at arm’s length, under terms and conditions that would have been made between persons dealing at arm’s length.   ...

She then calculated the amounts owed by both parties and agreed to make the support retroactive to November 1, 2008, the date on which she considered that custody for the child G changed. ...

The Respondent said that the evidence showed that the Appellant was “enrolled on a part-time basis but worked on a full-time basis. [14]     The Appellant’s counsel submitted that, although the University considered the online MBA program a part-time program, this was not determinative. ...

In that case Reed, J. considered and rejected a contention that the dispensing of prescription drugs in tablet and capsule form was''processing" within the meaning of section 125.1 of the Act. ...

Counsel also argued that when a loan is forgiven it need not be part of a severance package for the amount to be considered a benefit arising out of the employer/employee relationship. ...

The appellant said he considered that a betrayal. This resulted in an intense conflict between the principal shareholders of Relais Nordik Inc. that became known to the main players in the area’s shipping industry and ended up jeopardizing the service contract itself. ...

Additionally, if the respondent [sic] is alleging certain facts in his written or oral argument that were not considered by the respondent in making or preparing the assessment, but which may have an effect on the outcome of the proceeding, he must present evidence of them as in any other civil action. ...

On August 20, 1998, the Minister issued the Appellant a Canada Child Tax Benefit Notice informing her that, until she provides her spouse's name and social insurance number, she would not receive any further Child Tax Benefit payments and that the payment received with respect to July 1998 would be considered an overpayment. *               Partly admitted in Reply but fully admitted at commencement of hearing. [3]            The Appellant was the only witness to testify. ...

  [21]          However, in spite of the breadth of “business”, Heneghan J. ruled that a visa officer’s notes should not be considered records made in the ordinary course of business in Walia v. ...

Among the decisions cited by counsel for the appellant, I also considered the decision of the Supreme Court of Canada in Irving Oil Ltd., Foster Wheeler Ltd. and Canaport Ltd. v. ...