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The Court has considered four options. The first is to seal the entire file. ...

In Jabel Image Concepts Inc v Canada, [2000] GSTC 45, the Federal Court of Appeal wrote at paragraph 12: When an Act uses different words in relation to the same subject such a choice by Parliament must be considered intentional and indicative of a change in meaning or a different meaning. [22] In the case of paragraphs 254(2)(b) and (g), it must be presumed Parliament intentionally chose to make a distinction when it used the words “primary place of residence” in paragraph (b) and “place of residence” in paragraph (g). ...

He wrote as follows: [50] The subjective nature of the wilful blindness standard also means that the personal attributes of the individual may be considered in determining whether the individual is wilfully blind. [51] In contrast, the objective nature of the gross negligence standard means that the personal attributes of the individual are not relevant unless the individual establishes that he or she is incapable of understanding the risk the individual has failed to avoid (see R. v. ...

  [28] Under the case law, the tests to be considered to determine whether a default judgment should be set aside are the following:   a) the ongoing intention to pursue the appeal;   b) the appeal must be well-founded, that is to say that the appeal must be arguable. ...

A notice … is considered to be made available if it is posted by the Minister in the individual’s secure electronic account and the individual has authorized that notices or other communications may be made available in this manner and has not before that date revoked that authorization in a manner specified by the Minister. [25] Ms. ...

Canada [1986] 3 FC 553 (“Wiebe Door”). [36] The parties’ intent, along with the actual behaviour of the parties and any written agreement between them will be considered a second time. ...

Self-represented litigants [20] The Federal Court of Canada considered this question in Dionne v. ...

These issues considered, there shall be no costs in this General Procedure appeal. ...

If the election was validly made, certain taxable supplies between the companies that made the election are considered to have been made for no consideration. [3] There is no disagreement regarding the calculation of the amounts assessed. [4] Either the appellant could make the election and the appeal must be allowed or the appellant could not make the election and the appeal must be dismissed. ...

This is considered below. C. Extension Application [37] I must now determine whether to accept this Extension Application and thus allow the Applicant to file his various objections past the normal 90-day objection period. [38] Subsection 165(1) of the Act reads as follows: 165 (1) A taxpayer who objects to an assessment under this Part may serve on the Minister a notice of objection, in writing, setting out the reasons for the objection and all relevant facts, (a) if the assessment is in respect of the taxpayer for a taxation year and the taxpayer is an individual (other than a trust) or a graduated rate estate for the year, on or before the later of (i) the day that is one year after the taxpayer’s filing-due date for the year, and (ii) the day that is 90 days after the day of sending of the notice of assessment; and (b) in any other case, on or before the day that is 90 days after the day of sending of the notice of assessment. ...