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  [12]            This particular ATR was considered by the GAAR Committee, a specialized committee within CRA Rulings. ... [At paras 50-51]   [25]            My colleague Justice Luc Martineau also considered a jeopardy order issued pursuant to the Act in Canada (National Revenue) v Robarts, 2010 FC 875, 374 FTR 87. ... [At paras 35 and 41]   [26]            The Federal Court of Appeal considered the disclosure obligation in section 231.2 proceedings in R v Derakhshani, 2009 FCA 190, 2010 DTC 5043. ...

)       [2]                Two recent decisions emanating from the Tax Court of Canada and the Federal Court of Appeal have noted: [20]       Scholars have considered the concept of "power of direction or control" and its flip side, the relationship of subordination ... )   [44]            Two recent decisions emanating from the Tax Court of Canada and the Federal Court of Appeal sought to clarify the last characteristic constituting the element of a contract of employment, noting: “ Scholars have considered the concept of "power of direction or control" and its flip side, the relationship of subordination. ... [65]            Paragraph 242(3.1)(a) reads as follows: Limitation on complaints 242(3.1)      No complaint shall be considered by an adjudicator under subsection (3) in respect of a person where   (a) that person has been laid off because of lack of work or because of the discontinuance of a function; or   (b) a procedure for redress has been provided elsewhere in or under this or any other Act of Parliament.   ...

Even subtracting just the property taxes from the monthly expenses would give the applicant a surplus of $246. [18]            All that considered, the officer recommended that the request be denied. ... The respondent objected to the extent of disclosure and produced in the tribunal record only those documents considered by the decision maker. ... On this issue, the record is defective, since the officer said he considered the 2010 tax return for the bed and breakfast in the fact sheet and I assume that the manager did the same, but that return is not in the record. ...

(b) could not properly have been considered useless. The possibility would have remained of an extension by one or more provinces of their taxation of mining profits to processing profits. ... It must now be considered that in para. (a) the expression used to described the taxes for which a deduction may be allowed is “taxes paid, in respect of his income derived from mining operations in the province”. ... I do not doubt that it is in pari materia and should be considered, if necessary, in construing the regulations just as the Rome Convention was considered in construing the Copyright Amendment Act intended to implement it. ...

I have not considered the provisions of the amending Act which are objected to, and make no comment as to those provisions. ... On their interpretation of the reasons given in that case, this Court would have considered, as evidence admissible for the purpose of establishing the true object and nature of the municipal by-law giving rise to the litigation, two letters addressed to the members of the Municipal Council prior to the adoption of the by-law. ... [Page 795] The evidence relevant to the issue and considered in the Birks case did not include these letters nor was it evidence of a character similar to that which is objected to in the present case. ...

Rather, I have considered these submissions in the context of the Attorney General’s submission that the continuous course of conduct must be on-going at the time the applications are heard. [32]   The Applicants assert that the repeal of section 14 of the Regulations has not impacted section 12 of the Act and how the PMRA may use section 12 notices in the future. ... The applications concern the proper interpretation and application of legislation, which are matters amenable to the Court and not the PMRA. [47]   I have considered the submissions made by the parties as to whether the PMRA’s on-going proceedings afford the Applicants an adequate alternative remedy. ... Rather, the alternative processes that the Respondents urge this Court to accept as providing an adequate remedy were commenced independent of the Applicants, and are distinct from the conduct that is being challenged in these applications. [48]   Having considered the factors detailed in Strickland and the submissions of the parties, I am not certain that the Applicants have recourse to adequate and effective relief through the PMRA’s on-going proceedings. ...

Whether the services are rendered under a single contract, or for a single undivided consideration, are matters to be considered, but for the reasons given above are not conclusive. ... It must be considered whether in substance and reality the collection and disposal service are so intertwined and interdependent that they must be supplied together. ... Whether the services are rendered under a single contract, or for a single undivided consideration, are matters to be considered but are not conclusive. ...

Justice Campbell Miller was of the view that the charity’s address as indicated on the official receipt could not be considered as the place of issuance of the receipt. ... The receipts being considered here must show not only the address of the organization as recorded with the Minister, as required by paragraph 3501(1)(a) of the Regulations, they must also show the place or locality where the receipts were issued as required by paragraph 3501(1)(d). ... The purpose of this first stage of the test is simply to distinguish between commercial and personal activities, …  [W]here 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.  53 ...

It is also the case that the parties’ mutual intention or stipulation as to the nature of their contractual relations should be considered and may prove to be a helpful tool in interpreting the nature of the contract for purposes of characterizing it under the Civil Code. ... Canada, 2009 FCA 47, 2009 DTC 5056, wherein the intention of the parties is described as an important factor to be considered in characterizing a contract for purposes of the Civil Code. ... Conclusion [36]          Having considered all of the relevant facts as they relate to the parties’ intention and the indicia or considerations of subordination and control, tools and supplies, and financial risk and opportunity, I conclude that the relationship between Ms.  ...

Keshmiri works as a millwright and industrial electrician and was clear in stating that he considered himself to be self-employed. [19]   He currently has a registered company and issues invoices through his company, [20] but this company did not exist when he was working with European Staffing. [10]   Mr. ... Pajecki did not understand what it meant to be a subcontractor and considered himself to be an employee. [48] He testified as follows: “That time I need a job. ... Kenny testified that he was never told that European Staffing considered him to be a contractor until he sought his record of employment from them following his being laid-off. [115]   Ms. ...