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However, nowhere is it stated that non-compliance with the statute voids a reported dividend for the purposes of a section 160 assessment. [23]   In Larouche v R, 2010 FCA 32, the Federal Court of Appeal considered a similar case in which a taxpayer argued the treatment of a dividend must be determined based on principles of provincial corporate and civil law. ...

While I have read and carefully considered this material, I find that it is general in content and does not establish that the applicant by virtue of her circumstances faces a personalized risk in Hungary. ...

The Officer provided ample justification for her decision. [26]   In Officer Hardy's decision, he considered Mr. ...

      [18]   The Minister submits that the lack of corroboration noted by the RAD could be considered, owing to Mr. ...

The Minister considered the unreported amounts as being shareholder benefits. ...

(RBBSI apparently considered it had reached the end of the applicable one year period when in fact only nine of the twelve months comprising that statutory period for launching a time extension application had passed.) ...

Regardless I cannot find that CRA’s “ special mail services request form ”, albeit presumably with a Canada Post “ tracking number ” stamped or affixed thereon, can reasonably be considered, “ the post office certificate of registration of the letter or a true copy of the relevant portion thereof ” per subsection 335(1). ...

However, it is clear from the letter of the Minister’s delegate dated February 4, 2020 that the Applicant’s financial information, including his assets, liabilities, income, debt payments and CRA arrangements, was all considered. [33] A Taxpayer Relief Fact Sheet prepared in relation to the Applicant noted that he owed taxes in the amount of $123,582.87 as of November 18, 2019. ...

After reviewing the appellant's 1982 income tax return, the Edmonton office of RCT sent a letter to the appellant dated March 27, 1984 stating that a penalty under subsection 163(1) of the Income Tax Act was being considered and inviting the appellant to provide any information or explanation which might establish that the penalty was not applicable. ...

If the clientele or goodwill is considered property within the context of paragraph 12(1)(g), it may then be said that the amounts received by Mr. ...