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However, counsel for the appellant contends that the wording of Section 15A is ambiguous in the use of the words ‘‘other company or companies’’ and that resort must be had to statements made by the Minister of Finance at the time the legislation was being considered in Parliament. ...

(the ITA). [3] The Tax Court considered the evidence presented by both parties. ...

When applying the reasonableness standard, it is not the role of the reviewing court to reweigh or reassess the evidence considered by the decision maker or to interfere with factual findings unless there are exceptional circumstances (Vavilov at para 125). ...

I agree. [18] In my opinion, the record shows that the officer considered all the documents Mr. ...

I have considered the parties’ agreement but in the exercise of my discretion and in the circumstances of this case, I will order payment of $250.00 to the Respondent as costs.   ...

Decision under review [12] The Applicant applied for a second review of his eligibility to the CERB (the Second-Level Review). [13] The Second-Level Review officer considered, in addition to the documentation that was before the First-Level Review officer, the documents provided by the Applicant on July 29, August 27 and October 24, 2022: (a) A copy of a notice of assessment for the 2019 taxation year; (b) A copy of a notice of assessment for the 2020 taxation year; (c) A copy of a T4 slip for the 2019 taxation year from 9260-0535 Québec Inc. for $10,648.50; (d) Twenty-five pay slips with no date from 2021; (e) Twenty-six dated pay slips for the 2021 taxation year. [14] The Second-Level Review officer reiterated the Agency’s request to obtain invoices and bank statements from 2019 in order to confirm the $10,000 of other income self-reported by the Applicant. ...

Canada, 2013 FCA 122 at para. 7; TCC Reasons at paras. 27-28. [8] The Tax Court considered the respondent’s arguments in support of its motion to strike: (a) that the Tax Court does not have jurisdiction to review whether the Senate validly passed the EAP 2014 Act, as this is within the exclusive jurisdiction of Parliament; and (b) the Senate vacancy argument. [9] The Tax Court declined to strike the relevant passages on the basis of the jurisdiction argument: TCC Reasons at paras. 30-43. ...

Overview [1] The Canadian Government established the Canada Recovery Benefit [CRB] to provide income support for individuals who lost their employment during the COVID-19 pandemic by enacting the Canada Recovery Benefits Act, SC 2020, c 12, s 2 [CRB Act]. [2] Under the CRB Act, individuals who had applied for and received Employment Insurance [EI] benefits were considered ineligible for CRB although the legislation as it currently stands provides an exception for individuals who had received parental and maternity benefits: subsection 3(1)(h), CRB Act. [3] Mr. ...

The statutory provision to be considered is the same as in the Eastern Textiles Ltd. case {supra), namely, Section 26(1) (d) of the Income Tax Act, S.C. 1948, e. 52, as amended in 1949. ...

The appellant produced as exhibit A-1 financial statements concerning the 1972, 1973 and 1974 taxation years in which the $50,000 appeared as an asset: “Investment loan Secor Industries—$50,000’’. 3.5 The appellant was the president of the two companies. 3.6 During the taxation years in question the appellant borrowed from Secor Industries Limited and reimbursed the following monies: Year Borrowed Repaid Repaid Amount Owing 1970 $11,113.42 $ 3,000.00 $ 8,113.42 1971 $11,663.42 $11,113.42 $ 550.00 These figures were admitted by the appellant. 3.7 During the taxation years in question, Anndean Holdings Ltd borrowed from Secor Industries Limited and reimbursed the following monies: Year Borrowed Repaid Repaid Amount Owing 1970 $22,215.45 $ 8,100.00 $14,215.45 1971 $32,215.45 $22,215.45 $10,000.00 As the appellant owns 50% of the common shares of the company, the respondent included in his income $7,057.72 in the 1971 taxation year and $5,000 in the 1972 taxation year. 3.8 According to Mr Noël Frenette, witness for the respondent, those figures had not been disputed by the appellant before. 3.9 According to the appellant, however, the amounts not paid by Anndean Holdings Ltd must in fact be considered as reimbursements made by Secor Enterprises Limited to Anndean Holdings Ltd on the loan of $50,000 made by Anndean Holdings Ltd (see paragraph 3.4). 4. ...