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 (1)  Where at any time in a taxation year a benefit is conferred on a shareholder, or on a person in contemplation of the person becoming a shareholder, by a corporation otherwise than by   (a)        the reduction of the paid-up capital, the redemption, cancellation or acquisition by the corporation of shares of its capital stock or on the winding-up, discontinuance or reorganization of its business, or otherwise by way of a transaction to which section 88 applies,   (b)        the payment of a dividend or a stock dividend,   (c)        conferring, on all owners of common shares of the capital stock of the corporation at that time, a right in respect of each common share, that is identical to every other right conferred at that time in respect of each other such share, to acquire additional shares of the capital stock of the corporation, and, for the purpose of this paragraph,   (i)         where   (A)       the voting rights attached to a particular class of common shares of the capital stock of a corporation differ from the voting rights attached to another class of common shares of the capital stock of the corporation, and   (B)       there are no other differences between the terms and conditions of the classes of shares that could cause the fair market value of a share of the particular class to differ materially from the fair market value of a share of the other class,   the shares of the particular class shall be deemed to be property that is identical to the shares of the other class, and   (ii)        rights are not considered identical if the cost of acquiring the rights differs, or   (d)        an action described in paragraph 84(1)(c.1), 84(1)(c.2) or 84(1)(c.3),   the amount or value thereof shall, except to the extent that it is deemed by section 84 to be a dividend, be included in computing the income of the shareholder for the year.       ...

Semenov the benefit of the doubt, I have considered whether the US$9,000 allegedly paid by Valeriy to Mr. ...

In any given case, the place where the tangible personal property is delivered or made available may be determined by reference to the place where the tangible personal property is considered to have been delivered under the law of the sale of goods applicable in that case. 9. ...

The way in which the proposed amendment is drafted leads me to conclude that the purpose behind it is to have an assessment pursuant to section 160 considered as a distinct assessment with regard to which interest could accrue. ...

As such, personal attributes (subjective belief or personal characteristics) of the taxpayer may be considered in determining whether a taxpayer is wilfully blind. ...

As such, the Appellants dedicated their resources and assembled the assistance of their counsel and accountants with respect to the questions/irregularities the Respondent considered outstanding within the close of the discovery period, namely the date to satisfy undertakings agreed to between the parties and ordered by the court. ...

While a failure to inquire may be evidence of recklessness or criminal negligence, as for example, where a failure to inquire is a marked departure from the conduct expected of a reasonable person, wilful blindness is not simply a failure to inquire but, to repeat Professor Stuart’s words, “deliberate ignorance”. [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. ...

The Queen, Justice Lyons considered what “arranging for” meant in the context of credit card transactions. ...

It is clear that the addition of the Exclusionary Paragraphs (r.4) and (r.5) intend to limit the scope of Inclusionary Paragraphs, such as paragraph (l). [19] Prior to the 2010 amendments, the term “arranging for” as used in Inclusionary Paragraph (l) was construed expansively in a number of court decisions. [15] In some cases, a supplier to a financial services provider could be considered as arranging for a “financial service” without playing a direct intermediary role in the delivery of a financial service to a client of a financial institution. [16] For example, a supplier to a financial institution that performs a credit check or promotes the sale of a financial service or participates in its design might fall within the ambit of that language. [17] [20] Parliament addressed the courts’ expansive interpretation of Inclusionary Paragraph (l) of the “financial service” definition with legislative proposals intended to clarify that definition. [18] These proposals resulted in the additions of the new Exclusionary Paragraphs, including paragraphs (r.4) and (r.5). ...

Karda also argued that a reassessment that disallowed all the deductions that he had claimed could not be considered valid, if the sole purpose of the reassessment was to meet the limitation period. ... Consequential assessment (4.3) Notwithstanding subsections (4), (4.1) and (5), if the result of an assessment or a decision on an appeal is to change a particular balance of a taxpayer for a particular taxation year, the Minister may, or if the taxpayer so requests in writing, shall, before the later of the expiration of the normal reassessment period in respect of a subsequent taxation year and the end of the day that is one year after the day on which all rights of objection and appeal expire or are determined in respect of the particular year, reassess the tax, interest or penalties payable by the taxpayer, redetermine an amount deemed to have been paid or to have been an overpayment by the taxpayer or modify the amount of a refund or other amount payable to the taxpayer, under this Part in respect of the subsequent taxation year, but only to the extent that the reassessment, redetermination or modification can reasonably be considered to relate to the change in the particular balance of the taxpayer for the particular year. ...