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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. ...

Hours of Insurable Employment — Methods of Determination 9.1  Where a person's earnings are paid on an hourly basis, the person is considered to have worked in insurable employment for the number of hours that the person actually worked and for which the person was remunerated. 10(3)  Where the number of hours agreed to by the employer and the worker or group of workers under subsection (2) is not reasonable or no agreement can be reached, each worker is deemed to have worked the number of hours in insurable employment established by the Minister of National Revenue, based on an examination of the terms and conditions of the employment and a comparison with the number of hours normally worked by workers performing similar tasks or functions in similar occupations and industries. ...