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When all of the eligibility requirements are met and a specified member of a qualifying group elects, at any time on or after January 1, 2015, jointly with another specified member of the group, certain taxable supplies made between them are considered to have been made for no consideration.   ... When all of the eligibility requirements continue to be met and parties to an existing election with an effective date before January 1, 2015, that is still in effect on January 1, 2015, continue to elect jointly with each other, certain taxable supplies made between them after 2014 are considered to have been made for no consideration. … Parties to an existing election with an effective date before January 1, 2015, that is still in effect on January 1, 2015, are also required to file the election form.   ... The record also shows that he changed his view once all of the facts were considered. [31]   The decision under review was made by the Minister’s Delegate, the Assistant Director, Audit on September 11, 2018, and I am satisfied that the Denso Companies had sufficient information to know the CRA’s concerns and the case it had to meet.   ...

As such, the Respondent has not made submissions on this, and it will not be considered by the Court. ... In addition, the Applicant stated that the Further Second Reviewing Officer misapprehended or failed to consider the Applicant’s submissions and supporting documentation. [45] The Respondent stated that the record demonstrates that the Further Second Reviewing Officer clearly considered all submissions and supporting documentation. ... The Applicant knew the case she had to meet, and she was given a full and fair opportunity to make submissions, which the Further Second Reviewing Officer considered. [64] The Applicant made numerous bald assertions of other breaches of procedural fairness, including allegations of bias, misfeasance of public office, and misrepresentations, threats, and intimidation by CRA officers conducting the review of her application. ...

In Abreo, [6] the court considered good faith participation in a charitable donation tax scheme and an alleged CRA “duty to warn” (discussed further below). ... In an effort to be as fair as possible to the Appellant, I considered his written submissions and the arguments therein as supplements to his oral arguments. ... Taxpayer Bill of Rights [40] In Azzopardi, [17] this Court considered whether the Minister had a duty to warn taxpayers pursuant to the Taxpayer Bill of Rights that the CRA published. ...

The prevailing rate of inflation, the operating expenses of Gerbro and the annual expenses of Marjorie Bronfman were considered in order to arrive at this target rate of return. ... In light of the words “it may reasonably be concluded” preceding the description of the Motive Test in section 94.1, what is to be considered is whether it is objectively reasonable to conclude that such a benefit was contemplated. ... Whether it may reasonably be considered that Gerbro in fact obtained the contemplated benefit is a factor to be taken into account under paragraph 94.1(1)(d), but is not the only factor. ...

Specifically, Cooper revisits the Anns test and clarifies the express policy components to be considered at each stage. 9. ... Dutton and Rumley therefore establish the principle that a question will be considered common if it can serve to advance the resolution of every class member’s claim. ... The Defendant argues in particular that nothing in the Plaintiff’s material suggests that he has considered whether any individual Class Member could prove causation. ...