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It proposed the same language for the exemption, including the phrase “composed wholly of” that was ultimately enacted by Parliament. [21] The explanatory notes accompanying the Notice of Ways and Means Motion mimic the “composed wholly of” language of the exemption. [22] [59]         The exemption was ultimately added to the Act in 2007, with effect after June 2006. [23] [60]         There is nothing in the history of the exemption that suggests that Parliament ever considered employing an Agricultural / Plant Ingredients Test. ...

The penalties will be vacated as they are in no way justified in view of the quality of the Appellant’s evidence: ●                the good faith of the Appellant’s shareholders; ●                the highly acceptable quality of their bookkeeping and accounting; ●                the quality and credibility of all of the Appellant’s witnesses; ●                the preponderance of the evidence; ●                the willing and unlimited cooperation of the Appellant’s representatives with the auditor and the objection officer; ●                the very close management of the administration; ●                the involvement of the highly competent accountant. [143]    The Respondent questioned and disputed the Appellant’s decision to delay the purchase of an ideal electronic system for the “takeout orders” component on the pretext that that purchase would cost very little in comparison to the overall investment in the business. [144]    Were the context disregarded, this criticism might be valid and be recorded as a point on the negative side. [145]    Considered in context, however, that criticism is not as significant as argued by the Respondent. [146]    The only fact that might call for the imposition of a penalty is the observations of Mr. ...

It may be said that the appellant was naive, but in my view, his conduct, in light of what Solutions 21 told him, was not so reprehensible or unreasonable to be considered grossly negligent. [170]      Overall, the appellant may have been naive by participating in the programs offered by Solutions 21. ...

Can certain purchases deemed to be personal by the Minister be deducted in the calculation of the Corporation’s revenues and not considered as benefits conferred by the Corporation on Mr. ...

Andrews reviewed and considered relevant for establishing her assessing position. ...

Relevant Case Law on Subsection 97(2) and ACB of Partnership Interest [18]   The correctness of the specific interpretation of subsection 97(2) adopted by the Appellant in this case does not appear to have been judicially considered previously. ...

Rondeau participated in a simulation, which is the issue that needs to be considered when addressing the second issue. ...

The net result is that the Appellant will be considered to have given consideration equal to 26.21% of all of the amounts remaining in issue (after taking into account the concessions made by the Appellant) for the payments he received from Global. ...

., 2014 SCC 53, [2014] 2 S.C.R. 633 (“ Sattva ”). [34] There, the Court explained the role of the surrounding circumstances in the interpretation of a contract, as follows: While the surrounding circumstances will be considered in interpreting the terms of a contract, they must never be allowed to overwhelm the words of that agreement (Hayes Forest Services, at para. 14; and Hall, at p. 30). ...

Datu testified that all of the expenses were considered valid; Mr. Tong had provided her with receipts for the various expenses and the salary expense claimed matched the T4s issued to Mr. ...