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These circumstances must be taken into account, but must be considered against an objective "reasonably prudent person" standard. ...

Even if the testimony is considered to be reliable, I am not satisfied that it is a reasonable excuse for late filing the 2008 income tax return ...

“Natural person” argument   [21]          The “natural person” argument has already been considered on many occasions by the Tax Court of Canada, the Federal Court of Canada, the Federal Court of Appeal and the Superior Courts and Courts of Appeal of the provinces and by many Provincial Courts ...

Where paragraph (b) is applicable, then the tuition must be paid in respect of a course at least 13 consecutive weeks long. [8]               In four recent decisions, this Court has considered whether individuals taking online courses through the University of Phoenix were enrolled at an educational institution in Canada. [9]               Beaubier J. in Robinson v. ...

There may be deducted in computing a taxpayer's income for a taxation year such of the following amounts as are applicable:   …   (j.04) the total of all amounts each of which is an amount paid in the year by the taxpayer to a registered pension plan as   (i) a repayment under a prescribed statutory provision of an amount received from the plan that   (A) was included under subsection 56(1) in computing the taxpayer's income for a taxation year ending after 1989, and   (B) can reasonably be considered not to have been designated by the taxpayer for the purpose of paragraph (j.2), or   (ii) interest in respect of a repayment referred to in subparagraph (i),   except to the extent that the total was deductible under paragraph 8(1)(m) in computing the taxpayer's income for the year;   (emphasis added)   [10]          In this appeal it is not necessary to determine if all of the conditions for the application of these paragraphs are satisfied as both provisions only apply to amounts paid by the taxpayer. ...

He admits only the following facts stated in the notice of appeal:   (a)     The appellant purchased a parcel of land and a home;   (b)    A structure was built on land owned by the Appellant;   Since the Respondent admitted that the Appellant owned the property and since there was no motion to amend the Reply to withdraw this admission, the property, for the purposes of this appeal, is considered to be owned only by the Appellant. [2] Polley v. ...

The only concern is whether subsection 118(5) applies and this will be determined on the basis of whether or not John can be considered as being required to make support payments ...

The predecessor to the CRA considered the expenses to be personal, "a dream to make money with gold... there was no commercial activity". ...

And the definition of photograph "includes photo-lithograph and any work expressed by any process analogous to photography". [25]     Thus any original photographs, or digitally enhanced photographs, drawings or logos, which are a large part of the Website, should be considered artistic work. [26]     The definition of "compilation" is also instructive, as it may extend the meaning of "artistic work" by including: (a)         a work resulting from the selection or arrangement of literary, dramatic, musical or artistic works or of parts thereof, or (b)         a work resulting from the selection or arrangement of data; [27]     While the definition of an artistic work and other aforementioned definitions provide that a broad scope of works may be the subject of copyright, the Section 5 requirement, that the work be original acts to limit this scope. [28]     Until recently there was much debate over what constituted originality. ...

(e. 2)         such portion of the lesser of (i)             the premiums payable by the taxpayer under a life insurance policy (other than an annuity contract) in respect of the year, where                 (A) an interest in the policy is assigned to a restricted financial institution in the course of a borrowing from the institution,                 (B) the interest payable in respect of the borrowing is or would, but for subsections 18(2) and (3.1) and sections 21 and 28, be deductible in computing the taxpayer's income for the year, and                 (C) the assignment referred to in clause (A) is required by the institution as collateral for the borrowing and (ii)            the next cost of pure insurance in respect of the year, as determined in accordance with the regulations, in respect of the interest in the policy referred to in clause (i)(A), as can reasonably be considered to relate to the amount owing from time to time during the year by the taxpayer to the institution under the borrowing; [3]            The Minister submits that as an interest in the life insurance policy was not assigned to a restricted financial institution in the course of borrowing and the assignment was not required by the institution as a collateral for the borrowing; the Appellant is not entitled to deduct life insurance premiums pursuant to paragraph 20(1)(e.2) of the Act. [4]            The Appellant represented himself and was the only witness. ...