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It is even more improbable that they continued to stay at the Unit for an additional four months after the realization before returning to the Rockford property. [39]         Their testimony that they had not considered selling the Unit before February 2010 is contrary to the testimony by the appellant in cross‑examination that the photos of the Unit were taken on January 9, 2010, for posting in the MLS listing to sell the Unit. ...

As noted in Royal Winnipeg Ballet at para. 64, the relevant factors must be considered “in the light of” the parties’ intent. ...

The appellant requested more information from the CRA in respect of the proposed reassessment and, by letter dated August 24, 2012, the CRA advised the appellant that:   (a)        the $6 million loan was a shareholder benefit or an indirect payment for the benefit of the appellant resulting in an income inclusion under subsections 15(1) and 56(2) of the Act;   (b)        interest deductions were being denied as no amount of interest was paid or payable in the year; and   (c)        the CRA considered the $6 million loan to be a sham.   12.       ...

Each of these two conditions will be considered in turn.   Existence of a transfer   [27]         In this appeal, the Property seems to be have been transferred twice:   (a)     On December 14, 2007, pursuant to the Deed of Sale, Ms.  ...

The Queen, 88 DTC 6397, that when different parts of the same building are permanently used for what are considered to be two different purposes, the most important factor in determining the purpose for which the building is primarily used is the amount of space in the building that is used for each one of those two purposes. 12. ...

The decision considered the summary judgment rules in Ontario’s Rules of Civil Procedure. [26]         That approach is consistent with subsection 4(1) of the Rules which provides that the Rules “shall be liberally construed to secure the just, most expeditious and least expensive determination of every proceeding on its merits” and Rule 58. [27]          Hryniak, supra at paras 10, 49 and 66. [28]          Paletta, supra at para 34. [29]          Suncor, supra at para 26. [30]         McIntrye v Canada, 2014 TCC 111, 2014 DTC 1116 at para 25 and Delso Restoration Ltd. v Canada, 2011 TCC 435, 2011 DTC 1315 ...

In doing so, along with his explanation that both he and his ex-wife considered the wording to create mutual obligations to pay, he expected a positive response from the CRA. ...

This fact does not seem to have been considered by the CRA during its audit. [4]               [2002] RJQ 36, 2002 CanLII 41095 (QC CA). [5]               MacCallum v. ...

He concluded by saying that he had no strong argument to make in support of the penalties. [25]         I have considered whether Mr. ...

Konyi considered that Ms. Konyi’s dividend income from the family trust and her investments would be such during the course of 2006 that Ms. ...