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Headings may also be considered as preambles to the provisions they introduce…. [19]   I agree with Respondent counsel’s argument that the wording of subsection 8(1) should be interpreted in a fashion similar to the interpretation applied by Justice Paris in FLSmidth to subsection 20(12). ...

Given the similarity between the facts of the present appeal and those in Cheema, this appeal was ordered held in abeyance on February 17, 2017, pending the decision of the Federal Court of Appeal (“FCA”). [20]   In Cheema, Justice Smith considered a situation in which a friend of the taxpayer had acquired an undivided one percent interest in the property after co-signing with the taxpayer the agreement of purchase and sale and the application for mortgage financing. ...

In this case, whether they can be considered arranging for the transfer of ownership of shares by the appellant to its buyer.   ...

For the other two policies, benefits are based on the clinic’s overhead costs, that is, on the clinic’s real operating expenses, which is why monthly reports are required during the disability period. [21]   Since disability insurance premiums are considered personal expenses that cannot be deducted in computing the income of the insured under paragraph 18(1)(h) of the Act, the benefits paid under disability insurance policies are not taxable. [22]   With the exception of paragraph 6(1)(f) of the Act, which provides for the inclusion in computing an employee’s income of benefits received under a disability insurance plan to which the employer has made a contribution, the Act contains no provision for including disability insurance benefits in computing the income of a self-employed individual. ...

It raises the question why the Brost findings of fact should not also be considered in the proposed question, and not simply the findings of fact reflected in Kendall. ...

I do not doubt that these items were used [19] in the course of the Appellant’s employment, but I am not satisfied there was a contractual obligation on the Appellant to pay for these items. [26]   In addition, in the case of clothing or footwear these items are generally considered personal unless they cannot be worn generally; most of those expenses appear to be for items that can be worn generally. [27]   Finally, it also appears that, based on what the Appellant has since learned, he could have been reimbursed for some of these items. [20] Conclusion [28]   As previously stated, because of the absence of any T2200 forms, the appeal of the 2010 taxation year will be dismissed. ...

Moreover, the Minister does not appear to be concerned with the fact that there are two very different versions of the taxpayer’s attempts to resolve the matter: while the Applicant asserts that she tried to resolve the issue through the third party that assists her with filing her tax returns, and then later the CRA, the Minister asserts that the Applicant deliberately evaded CRA collections agents. [23]   I am of the view that, had the Minister considered the totality of the Applicant’s evidence, it is possible that she could arrive at a different conclusion. ...

The decision clarifies the mechanics of a number of provisions of the Income Tax Act that have not previously been considered and, in doing so, provides procedural certainty to both the Minister of National Revenue and taxpayers. [14]   In addition, it appears that the decision may have an immediate impact on the Sentinel Hill proceedings. [2] It is not my place to either analyze or describe what that impact may be. ...

Considering section 4 of the Rules and proportionality, if Parliament decided to choose a threshold of $50,000 and, at the same time, stated in subsection 17.3(3) that the Court must take into account other appeals for other taxation years if the appeal before the Court “ is likely to affect ” the other years, logically, if the aggregate of the amounts in issue for all of the years exceeds the threshold of $50,000 and if there are issues that are likely to affect the different years, the fact that the amounts in issue do not exceed $50,000 in each year considered individually has a narrower scope than if that were not the case. [8] While not applicable here, it is interesting to note that approaches in various jurisdictions can vary regarding how to limit costs. ...

Jacques Dufresne, it appears that the Corporation’s shareholders considered Ms. ...