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She explained in her working paper that “since the company paid the employees both the daily flat rate allowance and a per-kilometre rate allowance paid to the employees for the same day of work (same use), all amounts paid are considered unreasonalbe[sic] allowance and are taxable.” ...

Both provided submissions which have been where necessary considered by the Court for the purposes of these reasons.   ...

Whitney, 2002 FCA 266, the Federal Court of Appeal (FCA) considered whether compensation received by a New Brunswick government employee, while unable to work by reason of a work-related injury, came within the ambits of the aforementioned para. 56(1)(v) and subpara. 110(1)(f)(ii). ...

This, again, supports the conclusion that the Appellant never had a settled intention at any point in time to treat the Aurora property as his primary and permanent place of residence. [34]   Nor can it be considered a secondary residence in my opinion in respect to the Appellant's circumstances. ...

These reassessments were confirmed by the Minister of National Revenue (the “Minister”) on May 16, 2016, and the application for an order extending the time is dated October 24, 2018, or 29 months later. [2]   The Minister opposes this request. [3]   The Court considered the following essential facts: a)   On July 21, 2011, the Minister issued a notice of assessment for the 2009 taxation year. ...

Under the circumstances, the Form T2200 cannot be considered a determining factor in the appellant’s conditions of employment because the evidence leads to different conclusions. [36]   Based on an objective reading of the termination letter, there is no indication of any obligation on the appellant’s part to perform any duties or incur any expenses in order to receive the compensation provided in the letter, aside from returning the property of Planora he had in his possession in good condition. ...

The submissions regarding the $9,500 boat sale (paras. 1 to 5 of the "Final Submissions") were considered by me in addressing that topic above. [44]   Thus, having addressed the Appellant's points raised in his initial written submissions, I have found no basis to require any change to the result of the net worth assessments for 2011 and 2013. ...

CB described Exhibit A-2 as a collection of diagrams and pictures that provide a visual representation of the memorial niche and its execution. [9]   The Appellant considered three possible designs. ...

The respondent and the intervener maintain that this argument is supported by the fact that the appellant considered herself self-employed with Revenue Canada when she filed her annual tax return. [19]   Therefore, the fundamental issue is whether the long and detailed contract of employment is largely in keeping with the facts and circumstances surrounding the performance of commission work. [20]   To this question, I would answer “no”, based on the following elements established by the evidence. [21]   I am referring to the following elements in particular: 1.   ...

Kanagasabai in looking more closely at whether there were expenditures which could be considered business expenses of the Appellant. [33]   During Mr. ...