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Its relevance is only as evidence of the carefully considered efforts that were being made to resolve the differences. ...

The source of the unexplained funds could not be related to a non-taxable transaction and the funds were therefore considered to be taxable income as the most likely source was to be from the sale of narcotics. ...

., 64 DTC 5184, it has been assumed that the Crown could raise alternative bases for supporting an assessment even though they were not considered when the assessment was made. ...

              (2) Reasonable standby charge ─ For the purposes of paragraph (1)(e), a reasonable standby charge for an automobile for the total number of days (in this subsection referred to as the "total available days") in a taxation year during which the automobile is made available to a taxpayer or to a person related to the taxpayer by the employer of the taxpayer or by a person related to the employer (both of whom are in this subsection referred to as the "employer") shall be deemed to be the amount determined by the formula:             A/B × [2% × (C × D) + 2/3 × (E- F)]             where             A is the lesser of   (a)  the total number of kilometres that the automobile is driven (other than in connection with or in the course of the taxpayer's office or employment) during the total available days, and   (b)  the value determined for B for the year under this subsection in respect of the standby charge for the automobile during the total available days,   except that the amount determined under paragraph (a) shall be deemed to be equal to the amount determined under paragraph (b) unless   (c) the taxpayer is required by the employer to use the automobile in connection with or in the course of the office or employment, and   (d) all or substantially all of the distance traveled by the automobile in the total available days is in connection with or in the course of the office or employment;                   B   is the product obtained when 1,000 is multiplied by the quotient obtained by dividing the total available days by 30 and, if the quotient so obtained is not a whole number and exceeds one, by rounding it to the nearest whole number or, where that quotient is equidistant from two consecutive whole numbers, by rounding it to the lower of those two numbers;   C    is the cost of the automobile to the employer where the employer owns the vehicle at any time in the year;   D    is the number obtained by dividing such of the total available days as are days where the employer owns the automobile by 30 and, if the quotient so obtained is not a whole number and exceeds one, by rounding it to the nearest whole number or, where that quotient is equidistant from two consecutive whole numbers, by rounding it to the lower of those two numbers;   E    is the total of all amounts that may reasonably be regarded as having been payable by the employer to a lessor for the purpose of leasing the automobile during such of the total available days as are days when the automobile is leased to the employer; and    F    is the part of the amount determined for E  that may reasonably be regarded as having been payable to the lessor in respect of all or part of the cost to the lessor of insuring against          (a) the loss of, or damage to, the automobile, or        (b) liability resulting from the use or operation of the automobile.         15.(1) Benefit conferred on a shareholder ─ Where at any time in a taxation year a benefit is conferred on a shareholder, or on a person in contemplation of the person becoming a shareholder, by a corporation otherwise than by   (a) the reduction of the paid-up capital, the redemption, cancellation or acquisition by the corporation of shares of its capital stock or on the winding-up, discontinuance or reorganization of its business, or otherwise by way of a transaction to which section 88 applies,        (b)  the payment of a dividend or a stock dividend,        (c) conferring, on all owners of common shares of the capital stock of the corporation at that time, a right in respect of each common share, that is identical to every other right conferred at that time in respect of each other such share, to acquire additional shares of the capital stock of the corporation, and, for the purpose of this paragraph,   (i) where   (A) he voting rights attached to a particular class of common shares of the capital stock of a corporation differ from the voting rights attached to another class of common shares of the capital stock of the corporation, and     (B) there are no other differences between the terms and conditions of the classes of shares that could cause the fair market value of a share of the particular class to differ materially from the fair market value of a share of the other class,     the shares of the particular class shall be deemed to be property that is identical to the shares of the other class, and   (ii) rights are not considered identical if the cost of acquiring the rights differs, or     (d) an action described in paragraph 84(1)(c.1), 84(1)(c.2) or 84(1)(c.3),   the amount or value thereof shall, except to the extent that it is deemed by section 84 to be a dividend, be included in computing the income of the shareholder for the year ...

  [11]      In drawing the line between "ordinary" negligence or neglect and "gross" negligence, a number of factors have to be considered. ...

The Minister of National Revenue, [36] three conditions must be satisfied before an arrangement will be considered to be an EPSP under subsection 144(1): (a)   Payments must be computed by reference to the profits of the employer’s business. ...

.), wherein Cattanach J. considered the application of subsection 56(2) and set out each of the essential ingredients which must be met in order for the subsection to apply. ...

Her Majesty the Queen, 2010 TCC 634, Justice Boyle considered both theories and chose to adopt the opinions of Houlden and Morawetz and of Deslauriers, relying on the decision rendered in Anderson v. ...

When this happens the asset is considered to have been transferred from the wrong class to the correct class as of the beginning of the year being reassessed. ...

Was the Minister of National Revenue right to disallow the input tax credit concerning a debt the appellant considered bad? ...