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I have therefore not considered whether this claim was appropriate. I note in passing, however, that in 1992 the trusts foreclosed on the mortgage and obtained a final order of foreclosure on November 23, 1992. ...

Kaur testified that the CRA considered 1444932 Ontario Limited to be the designated member of the Partnership; [18] and Mr. ...

Accordingly, the Appellant was not entitled to a deduction of motor vehicle expenses incurred in respect of his employment by ParaMed for any of the Taxation Years. [62] The fact that the CRA may have considered a greater per kilometer allowance than that provided by ParaMed reasonable does not entitle the Appellant to deduct the difference under paragraph 8(1)(h.1) when the allowance was not included in income because of subparagraph 6(1)(b)(vii.1) and there is no evidence that the allowance was not reasonable. [17] [63] According to the T2200 forms issued to the Appellant by Spectrum, the motor vehicle allowance provided to the Appellant by Spectrum was not based solely on the number of kilometers driven by the Appellant in connection with his employment by Spectrum. ...

Dally insisted he always considered Ontario as a bare trustee. As far as the second issue in the appeals are concerned, Daily's only evidence was that neither he nor Lucio Sandrin, nor either of the individual appellants, was a trader or speculator but had purchased property in the past for investment purposes only. ...

" It is apparent from the affidavit of Jose Antonio Remedios, filed, that as a senior appeals officer of the Department of National Revenue, he deposed, inter alia (tabs E to O, inclusive, attached to the affidavit), that the Minister considered the objection to the subsection 227.1(1) assessment, reconsidered the assessment and decided to confirm the assessment on the basis that Giovanni Zen was a director at all material times and that other conditions of the section 227 had been met including that of the lack of "due diligence” by the appellants. ...

Spiro DATE OF JUDGMENT: July 24, 2024 APPEARANCES:   Counsel for the Appellant: Clifford Rand, Josh Kumar, and Monica Carinci Counsel for the Respondent: Lindsay Tohn and Linsey Rains   COUNSEL OF RECORD: For the Appellant: Name: Clifford Rand, Josh Kumar, and Monica Carinci   Firm: Aird & Berlis LLP Toronto, Ontario   For the Respondent: Shalene Curtis-Micallef Deputy Attorney General of Canada Ottawa, Canada     [1] Logical relevance is the first of four “ Mohan factors” to be considered in determining the admissibility of expert opinion evidence. ...

By excluding the expert report in its entirety presently, the Court risks depriving itself of: the complete evidentiary record that should be considered, and/or the necessary technical or scientific basis to come to a conclusion; or both, in the adjudication of Parts I and II of the Application. [19] However, the jurisprudence, and not the Rules, drives the analysis of whether or not to grant the Minister’s Motion. ...

This indicates that the power to seek production under section 86 is limited to documents, which would be considered relevant at trial. ...

E-15), as amended (hereinafter “the ETA”). [3] The appellant is appealing from the June 8, 2016, reassessments for the quarterly periods between January 1, 2014, and September 30, 2014 (hereinafter “periods at issue”). [4] The Minister of National Revenue (hereinafter “the Minister”) submits that the sales at issue are taxable supplies, given that the appellant has not obtained the required documentation for these sales to be considered zero‑rated supplies and has not maintained appropriate records. [5] Unless otherwise stated, all references to legislative provisions in these reasons refer to the legislative provisions of the ETA as concerns the reassessments and the periods at issue. [6] For the reasons that follow, the appeal must be dismissed. ...

Kalwa’s testimony was not reliable or credible regarding his excuses for not reporting because: (i) in a previous taxation year, he failed to report a disposition of capital property, and was reassessed, penalized and also warned of subsequent “red flagging”; (ii) he has a Master’s degree; is a Quality Assurance IT Manager, who previously held that role with major banks; and, is experienced in real estate (as of 2022 he is a licenced and self-promoting real estate broker); (iii) his asserted belief of a PRE option for Portsmith is belied by the fact he never resided at the property, did not file a T-2091 to report it, and already had a different principal residence at the same time in the same taxation year; (iv) the work done on Portsmith was consistent with short term resale, not long term occupancy with his family; (v) he reviewed his tax returns with his accountant, clearly reported two real properties disposed of in 2016, but omitted two others: Portsmith and Clarkhill; and, (vi) blaming his accountant does not stand up to scrutiny: he reviewed the tax return and, further, his tax preparer accountant did not testify; c) The additional outlays claimed in these appeals, even when considered, are not significantly applicable to Portsmith (the relevant penalty property), but rather Glenboro and 1404 Yonge (to which no penalty was levied), therefore the magnitude of the unreported gain from disposition is that much more noticeable. ...