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The evidence must be considered in relation to the test established by paragraph 225.2(2) itself and by relevant cases …. ...   [14]            An assessment of the jurisprudence requires the Court to stay close to the statutory scheme related to jeopardy orders, which in the period after initial enactment in 1985 underwent two or three amendments, shortly thereafter, changing the standard of proof from "it may reasonably be considered that the collection of the amount assessed…would be jeopardized" to "reasonable grounds for believing" such would be the case ... Fowles' affidavit considered by Justice Snider ex parte did not provide her with full and fair disclosure of the true value of her assets, a true picture of the refinancing efforts on the Bates Street and Hogarth Street residences and a full picture of the family's financial affairs, all of which should be viewed cumulatively. ...

In a letter dated May 19, 2010, the CBSA Recourse Directorate informed the Plaintiff that his request was accepted and his complaint was being considered. [9]                By letter dated October 20, 2011, the Minister found that the actions of the Plaintiff constituted a contravention of the Act under section 131 and that $7,051.12 of the amount paid by the Plaintiff for the return of his goods was to remain held as forfeit pursuant to section 133. The Minister found that the $4,000 initially declared by the Plaintiff was not considered in assessing the forfeit amount of $8,655.44 against the Plaintiff. ... In a letter dated June 8, 2010, the CBSA Recourse Directorate informed the Plaintiff that his request was accepted and his complaint was being considered. [17]            By letter dated October 19, 2011, the Minister found that the actions of the Plaintiff constituted a contravention of the Act under section 131 and that the $5128.48 was to be held as forfeit pursuant to section 133. ...

The goods to be re-investigated included certain oil country tubular goods considered in Inquiry No. ... BASIC PRINCIPLES RESPECTING INTERLOCUTORY INJUNCTIONS [15]            All parties cite and rely upon the decision of the Supreme Court of Canada in RJR-MacDonald Inc. v Canada (Attorney General), [1994] 1 S.C.R. 311, as setting out the fundamental requirements to be considered by the Court on an application for relief such as that requested here.  ... That Memorandum demonstrates that the factors set out in the CBSA Guidelines, described as D14-1-8, were considered and applied; see pages 2, 3 and 4 of the Memorandum.  ...

For example, although Hennelly remains the leading case setting out the factors to be considered to permit the Court to exercise its discretion to grant an extension, a fifth factor has evolved.  ... Justice Mahoney did refer to a requirement for a “fairly arguable” case but did not define that phrase nor provide any analysis of what would be considered “fairly arguable”.   ... DATED: MAY 25, 2016 CONSIDERED AT TORONTO, ONTARIO PURSUANT TO RULE 369 WRITTEN REPRESENTATIONS BY: Monica Bharadwaj For The Applicant Dorah Dorcine FOR THE RESPONDENT SOLICITORS OF RECORD: Monica Bharadwaj Barrister and Solicitor Toronto, Ontario For The Applicant William F. ...

In case the tax on the income proves to be greater in amount, the quarterly payments collected shall be considered to be in part payment of the tax payable on the income earned during the corresponding period. (2) In the case of ore producing mines which prove taxable on their output not yielding and realizing on ore a market value of five thousand dollars in any one year, and in the case of all mines (placer or dredging) which prove taxable on their output not producing a gross value of two thousand dollars in any one year, the taxpayer shall, upon a statement verified by him and certified by the assessor of the district, and forwarded to the Minister of Mines, be entitled to:— (a) A refund, in the case of ore-producing mines, of one-half of the tax paid; and (b) A refund of the whole tax in the case of placer or dredging mines. (3) Every person owning, managing, leasing, or working a gold mine, which shall for the purposes of taxation consist of a mine in which the market value of the gold recovered from ore is eighty-five per cent or more of the gross value of the metal content of such ore, shall be assessed and taxed on his income from the mine as provided in Part I: Provided that any mineral tax paid during the year 1917 may be applied to payment of the income tax levied in respect of the income from the mine during the corresponding period. ... This tax on the output is two per cent, and by the effect of the amendment, in case the tax on the income from the mine is greater in amount than the production tax, the quarterly payments of the latter tax are considered as part payment of the tax payable on the incomes from the mine. ... As a result, section 155 as re-enacted in 1918 must be considered with the provision I have just cited. ...

Section 224A(1)(a) as it then read provided: 224A. (1) In any proceedings under section 222 or 224, (a) where it is proved that the accused occupied the seat ordinarily occupied by the driver of a motor vehicle, he shall be deemed to have had the care or control of the vehicle unless he establishes that he did not enter or mount the vehicle for the purpose of setting it in motion;… In considering the contention that this section had the effect of depriving the accused of the presumption of innocence, this Court considered, amongst other cases, the judgment of Lord Diplock in the Public Prosecutor v. ... The effect of the opening words of s. 205(1) was considered by Chief Justice Porter speaking on behalf of the Court of Appeal of Ontario in R. v. ... When the evidence with respect to these exhibits is considered against the background of alleged gemological expertise said to have been obtained by the accused in the taking of a course from the Gemological Institute of America, it is to be remembered that the two stones P-4 and P-5 which he said he acquired for $800 and $400 respectively were valued by the expert called at the trial at $10,000 and $4,250. ...

Judgment had been reserved by the Court of Appeal at the conclusion of argument and nothing had been said with reference to the costs before the Mining Commissioner, it having been perhaps assumed that those costs would be considered by the Court of Appeal in the ordinary way. ... The attitude taken towards costs against the Crown, manifested in the two cited cases, is reinforced by the progression of legislation across the country putting the Crown in the position of an ordinary litigant; and this, in my view, is a factor to be considered in construing s. 10(6) of the Mining Tax Act in the narrow way that I would view it. ... Attorney-General of Nova Scotia [6], at p. 368, this Court considered a motion to vary the judgment in the case as settled by the Registrar by striking out an award of costs to the Crown in right of Nova Scotia. ...

Category (ix) in the appellant's motion grouped together advance rulings and technical interpretations, and the learned Tax Court judge considered them together.  ... While the former is applicable to proposed transactions considered in the context of the factual situation of a particular taxpayer, the latter focuses on specific problems of interpretation relating most often to words, clauses or sentences in a provision.  ... Further, and more importantly, when advance rulings are published, they are typically accompanied by the following caveat: Income Tax Rulings are published for the general information of taxpayers but are considered to be binding on the Department only in respect of the taxpayer to whom the ruling was given. [18]                                       In Minister of National Revenue v. ...

 (1) Subject to this Part, …   (b) a disability pension shall be paid to a contributor who has not reached sixty-five years of age, to whom no retirement pension is payable, who is disabled and who (i) has made contributions for not less than the minimum qualifying period, (2) For the purposes of paragraphs (1)(b) and (e), (a) a contributor shall be considered to have made contributions for not less than the minimum qualifying period only if the contributor has made contributions on earnings that are not less than the basic exemption of that contributor, calculated without regard to subsection 20(2), (i) for at least four of the last six calendar years included either wholly or partly in the contributor’s contributory period or, where there are fewer than six calendar years included either wholly or partly in the contributor’s contributory period, for at least four years, … (b) the contributory period of a contributor shall be the period (i) commencing January 1, 1966 or when he reaches eighteen years of age, whichever is the later, and (ii) ending with the month in which he is determined to have become disabled for the purpose of paragraph (1)(b), … (my emphasis) 44 ...   [29]            The application judge then considered the effect of subsection 30(5) of the Plan. ... ANALYSIS   [31]            The first issue to be considered is the standard of review ...

  [18]            Using a contextual and purposive analysis of the Excise Act, 2001 and of the Stamping and Marking of Tobacco Products Regulations, the Tax Court judge concluded that “[w]hen the Act and the Regulations are considered as a whole, and paragraph 2(b) of the Regulations is considered in light of its purpose, it is evident that the expression ‘offered for sale to the general public’ is intended simply to mean ‘offered for sale to those members of the general public to whom they may be legally offered’, or to put it another way, ‘offered for sale at the retail level’, or, as the parties expressed it in paragraph 15 of their Agreed Statement of Facts, ‘…offered for sale to consumers…’” (Reasons, at para. 19) ...       [22]            It is necessary to consider not only the ordinary and natural meaning of the words used, but also the context in which they are used and the purpose of the provision considered as a whole within the legislative scheme in which it is found: Bell ExpressVu Limited Partnership v. ...