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Timeliness [46] As indicated in Continental Bank Leasing, one of the factors to be considered by the Court, when determining whether a proposed amendment would serve the interests of justice, is the timeliness of the motion to amend. [33] Given that the Respondent had included paragraph 51 in her Reply in Chad II, which was filed on May 27, 2019, the current Motion to amend (so as to add proposed paragraph 39.1 and other provisions), notice of which was filed June 29, 2021, was anything but timely. ...

Szuch in 2008 as “Loan as per Receipt Book”. c) disallowed as a liability the $62,000 loan in 2008; d) summarized the personal expenses for the relevant years; [23] e) added $1,455 as “Net Rent Income” in 2007 as owners of 3 Robin Hood; [24] f) increased each Appellant’s income by $33,273 and $158,212 in 2007 and 2008, respectively, as unreported shareholder benefits conferred on them; and g) imposed penalties in the amounts of $9,129.22 and $27,973.05 for 2007 and 2008, respectively, on the unreported income. [39] By letter dated March 20, 2015, the Appellants requested that the Minister reconsider the amount of Advanced Funds included in the calculation, and submitted that 80% of the Advanced Funds should have been considered impaired in the relevant years. [40] On March 31, 2015, the Minister confirmed the reassessments and penalties for 2007. ...

This was the same issue considered by the Court in the Wheeler case. The Appellants there argued that both “discovery” and “accumulation” should be given their plain and ordinary dictionary meanings such that, at most, clause (ii.l)(A) adds a requirement that the well have the ability to produce petroleum or natural gas (irrespective of from what pool such production is attained). ...

You can ask him questions about what he looked at and what he considered, but it’s improper to ask us how – for our evidence on certain points. ...

In addition, even if these loans existed, they were not contemplated at the time of transfer of the interest in the Property, and thus, they cannot be considered as part of the consideration given by Ms. ...

This Court considered pa r agraph 8(1)(f) and wrote: [7] P aragrap h (1)(f) …refers to amounts expended. ...

In arriving at the answer to that question, I have considered the assumptions and the evidence under each criterion in turn. 1. ...

Doherty considered various offshore markets that SLAC might consider entering, and provided his recommendations to Mr. ... Furbert also signed an authorization for personal information also dated December 18, 2006, a date before she was even considered for the position and while the offer was pending to Ms. ...

They cannot succeed in that purpose unless they are considered to be mandatory requirements and strictly enforced. ... The Queen, 2015 TCC 182, [2016] GSTC 53, Associate Chief Justice Lamarre stated as follows: [28] As stated above, when there is an issue of gross negligence, the taxpayer’s conduct should be considered, especially if it must be determined whether the taxpayer was wilfully blind. ...

Likewise, there was no evidence to support the allegations in paragraphs 6(k), (l), (m) or (n), nor the conclusion reached in paragraph 6(o), even if the conditions referred to therein should be a factor to be considered in the contract of service argument. ... Some of the presumptions may have been rebutted and some may even have been supportive of the Appellants’ position but the ultimate result is that the significant allegations detrimental to the Appellants’ positions have not been rebutted and indeed could not have been rebutted without the evidence of the “Payor”. [413] Taken in isolation, the payment of wages in cash may not be significant, but when considered in light of the allegations of the Respondent in the Reply and in light of the failure of the Appellants to produce any corroborative evidence of payment, that fact is of significance. ...