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Rich enumerates several factors to be considered in making this determination. ...

The Queen, [1983] 1 S.C.R. 29, this is determinative with respect to the location of the appellants’ employment income. [4]                In the alternative, in the event of ambiguity about the application of this common law principle, other connecting factors may be considered to locate the situs of the appellants’ employment income, but the Judge erred in the application of those factors. [5]                In Horn v. ...

Accordingly, he concluded that, as a practical matter, the issue before him was the validity of the 10% penalties that were assessed against the Taxpayer under subsection 163(1) of the Act for 2009 and 2010. [4]                In the Tax Court of Canada, the Taxpayer asserted that he had never worked for, or been paid by, the three companies that issued the T4s to him in respect of the unreported amounts of income, and that he must have been a victim of Social Insurance Number fraud. [5]                The Tax Court Judge considered evidence of connections between the Taxpayer and the three companies that issued the T4s to him. ...

The Judge considered these submissions and, in our view, made no reviewable error in dismissing the appellant’s requested relief: reasons at paragraphs 12, 25. [10]            Even treating the motion on its own, we see no grounds upon which the application should have been struck. ...

These issues and provisions have been considered by this Court on numerous occasions and by the Federal Court of Appeal in its 2013 decision in Verones v. ...

"Peter Annis" Judge FEDERAL COURT SOLICITORS OF RECORD DOCKET: T-81-17 STYLE OF CAUSE: ELIZABETH BERNARD v MINISTER OF NATIONAL REVENUE MOTION IN WRITING CONSIDERED AT OTTAWA, ONTARIO PURSUANT TO RULE 369 OF THE FEDERAL COURTS RULES JUDGMENT AND reasons: ANNIS J. ...

Archibald to introduce fresh evidence should be considered. The Crown opposed this motion. ...

For the 2011 taxation year, the Minister considered a claim by Westsource for tax credits in respect of SR&ED for two projects. ...

The Queen, 2018 TCC 88, that a corporation cannot appear in person and must be represented by a lawyer in a general procedure appeal in this Court by virtue of section 17.1 of the Tax Court of Canada Act. [1] [4]   For this same reason given by Justice Graham on the first motions and by me in Suchocki Accounting, I am dismissing these motions. [5]   In any event, as noted in Suchocki Accounting, even if I am wrong with respect to the section 17.1 requirement that a corporation be represented by counsel in a general procedure appeal, Rule 30(2) would leave the matter in my discretion including as to the conditions that may apply with respect to any particular representative in any particular case. [6]   There is case law of this Court that helpfully identifies some of the matters to be considered in exercising my discretion in this regard. ...

The disbursements are justified and considered necessary and reasonable costs for the conduct of this case. ...