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., c. 1246, (the “Regulations”), are included in the pension income. [11]   Subparagraph 14(6)(a)(iii) requires that the applicant’s income for the base calendar year be calculated on the assumption that the applicant had no income from any office or employment or any business and no pension income. [12]   In calculating the Appellant’s estimated income for 2013, the Minister included the income drawn from her RRSP for 2012 under subparagraph 14(6)(a)(iii) of the OASA. [13]   Whether payments drawn from an RRSP constitute pension income as that term is defined for the purposes of the OASA, namely in section 14 of the Regulations, was considered in at least three other cases before this Court: − Drake v. ...

The evidence rather establishes that ISAF was set up by United Nations Security Council resolution in order to provide security assistance in the reconstruction of Afghanistan (Resolution 1386 (2001) and Resolution 1510 (2003), Exhibit R-1, Tab 12). [35]   In the alternative, even if ISAF were to be considered a subsidiary body of NATO, I agree with the Respondent that it is a military body, to which the Ottawa Agreement does not apply. ...

The Minister has the onus of establishing the facts that support the imposition of gross negligence penalties in these appeals. [20]   Respondent counsel referred me to the case of DeCosta v The Queen, 2005 TCC 545, 59 DTC 1436, where the then Chief Justice Bowman set out the factors that need to be considered when deciding whether evidence points to “ordinary negligence” of a taxpayer as opposed to “gross negligence.” ...

I did not request any further submissions on costs in my decision nor invited the parties to make any further submissions in the event they were not satisfied with my decision on costs, but the Appellant has brought a motion in writing for an award of costs by way of lump sum equal to 50% of its select counsel fees for 2 counsel totalling $281,827.65 inclusive of GST/HST which amounts to $140,913.83 together with $11,300 for bringing this motion for additional costs and disbursements of $1,591.94; all of which total $153,805.77. [2]   The Respondent agrees the Appellant should be entitled to a bit more than Tariff costs and argues twice the Tariff costs of $10,177.60 inclusive of disbursements should suffice. [3]   There is no dispute that Rule 147 grants the Court complete discretion in determining the amount of costs, their allocation and the persons required to pay them and that Rule 147(3) sets out the factors that the Court may consider in exercising such discretion which must be considered on a principled basis. ...

Analysis [15]   In written submissions, the Respondent argues that the Appellant “should have paid tax on the excess contributions to the RRSP pursuant to section 3 of the Act” and that the loss in the actual monetary value of the investments in the RRSP “does not impact the Appellant’s requirement to pay tax and should not be considered”. ...

In that decision, Deputy Judge Jorré considered what would happen if an employer refused to provide a T2200 to an employee. ...

As a result, the legal expenses incurred are considered a non-deductible personal expense for tax purposes. [21]   On cross-examination, the appellant acknowledged that he retired as a member of the Barreau on September 15, 2014 and, as such, could not practice law in 2015 even though he was registered on the Barreau’s roll as a retired lawyer. ...

According to her, the fact that the appellant did not become a shareholder of the Company in 2002 was simply a technicality that she considered unimportant. ...

The Officer concluded that the applicants were not credible and had not shown that they met the criteria to be recognized as Convention refugees, nor could they be considered persons in need of protection under IRPA sections 96 and 97. ...

The facts of this case are clearly distinguishable from those I recently considered in Zheng v. ...