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DiGiuseppe was considered by Romspen as the principal debtor on the mortgages under the terms of the guarantee and a Guarantor’s clause. ... Standard of Review [22]   The standard against which the discretionary orders of a Prothonotary are to be reviewed was recently considered by the Federal Court of Appeal in Hospira Healthcare Corporation v Kennedy Institute of Rheumatology, 2016 FCA 215 [Hospira Healthcare]. ... However, Romspen does not take the position that the Prothonotary erred in finding that Romspen was first in line to the surplus fund. [50]   Having concluded that Romspen was first in line, the Prothonotary reviewed and considered Romspen’s claim to the funds based on its priority. ...

Based on the agreement, the CRA considered the commission payments to be part of the selling price of the Quatre Saisons shares. ... She did not have an appraisal of the shares of Quatre Saisons done and she merely considered that the selling price of the shares was equal to the amount of the commissions paid by Quatre Saisons to Placeval. ... The parties considered the payments made by Quatre Saisons to Placeval to be commissions. ...

Thus, where the nature of a taxpayer’s venture contains elements which suggest that it could be considered a hobby or other personal pursuit, but the venture is undertaken in a sufficiently commercial manner, the venture will be considered a source of income for the purposes of the Act. ... The activities contained no elements that would suggest that they should be considered a hobby or other personal pursuit. ... As a result, the Appellant knowingly made a false statement or omission in his returns. [54]   It is also my view that the Appellant made the false statement or omission in each of his 2009, 2010 and 2011 tax returns in circumstances amounting to gross negligence. [55]   The phrase “gross negligence” as used in subsection 163(2) of the Income Tax Act was considered in the widely adopted decision of Venne v. ...

It considered only some of the grounds Ms. Hillier advanced in her application for leave, not all of them. ... Under any level of intensity of review, the Appeal Division’s decision is unreasonable. [41]   It follows that the Appeal Division should have considered and determined all of the grounds raised by Ms. ... I queried counsel as to whether the grounds not considered by the Appeal Division had any prospect of success. ...

Having considered the application and response records, as well as their additional comments, I find that the Order should be confirmed. [3]   The respondent has worked as a mortgage broker since 2000. ... Papineau made several calculation or presentation errors in the first affidavit, while the following additional facts and explanations from the respondent should be considered. ... Reasonable grounds to believe that a delay would compromise recovery [23]   I also considered all the evidence in the record and the relevant case law. ...

The Tax Court judge noted that the parties did not dispute that this condition was satisfied in this case. [20]   The third condition is that the requested change must reasonably be considered to relate to the change in the particular balance of the taxpayer for the particular taxation year. ... There is a further condition that the reassessment must reasonably be considered to relate to the change in the particular balance of the taxpayer for the particular year. [27]   Subsection 152(4.3) also provides that the Minister is to “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…”. ... In Sherway the interpretation of subsection 152(4.3) of the Act was considered. ...

The decision under review [13]   In view of the fact that the applicant conceded his membership in the BNP, the only issue to be considered is whether there are reasonable grounds to believe that the party is an organization that engages, has engaged or will engage in terrorism. [14]   The Immigration Division concludes that such reasonable grounds exist. ... Accepting the guidance of this Court in cases such as Ali v Canada (Citizenship and Immigration), 2017 FC 182; Kamal v Canada (Immigration, Refugees and Citizenship), 2018 FC 480; Alam v Canada (Citizenship and Immigration), 2018 FC 922, the ID finds that two definitions found in our law, at section 83.01 of the Criminal Code and in Suresh, should be considered. ... It seems to me that if an organization is using a “code” in calling for some events such that it can be reasonably inferred from the evidence that it intentionally causes death and serious injury, a proper finding of engaging in terrorism might be considered. ...

The Court gave it and the other parties an opportunity to make submissions. [6]   Having read and considered the parties’ submissions, the Court concludes that Tsleil-Waututh Nation has violated the Order granting leave. ... The consequences of Tsleil-Waututh Nation’s allegations of bias will be considered at the end of these reasons along with its violation of the Court’s order granting leave. ... This Court has considered and rejected this argument multiple times because this particular legislative regime is not designed to permit a series of piece-meal judicial reviews. ...

Rather, when considered globally, its activities are that of a construction company and therefore under provincial jurisdiction (Construction Montcalm). ... The relationship is to be considered “from the perspective both of the federal undertaking and of the work said to be integrally related, assessing the extent to which the effective performance of the federal undertaking was dependent on the services provided by the related operation, and how important those services were to the related work itself” (Tessier at para. 46). ... As such, the decision only reflects the wishes of the parties to the agreement, and does not reflect the considered opinion of the OLRB. ...

This begs the question: does the PBC decision adequately convey that it reasonably considered all information, and offer an intelligible and transparent justification for its final decision? ... Police reports are considered to have reliable and persuasive information: DLE v Canada, 2019 FC 909 [DLE] at paras 35-37, 40; Charalambous v Canada (AG), 2015 FC 1045 [Charalambous] at para 16. ... So long as the chain of reasoning of the decision maker can be understood, and it shows proper engagement with or consideration of the evidence, the decision will be reasonable: Oladihinde, supra at para 16. [33]   As detailed above, the alleged incident with the firearm was one of many factors the PBC considered before arriving at a final decision. ...