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Accordingly, when a non-profit organization 1s involved, this interest income, which the case law considers business income when a profit-making entity is involved, is considered by analogy to be operating income. ...

Fitzpatrick considered the admissibility of compelled self-reporting documents in a regulatory prosecution. ...

The following criteria should be considered: the profit and loss experience in past years, the taxpayer’s training, the taxpayer’s intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...

The meaning of “regular minister” was considered in depth in Walsh v. ...

That lack of exemplary consistency, which may be common and usual in such matters, was nevertheless ill-considered and unwise. ...

He also stated that hindsight and retrospective evidence were not to be considered and that he had to put himself back at the June 4, 1992 date and assume no knowledge after that date. ...

Where disclosure authorized (2) The head of a government institution may disclose any record requested under this Part that contains personal information if (a) the individual to whom it relates consents to the disclosure; (b) the information is publicly available; or (c) the disclosure is in accordance with section 8 of the Privacy Act. [36] Section 3 of the Privacy Act (RSC 1985, c P-21) lists the types of information considered to be personal information. [37] Section 3 also provides that certain information is not personal information within the meaning of the ATIA, and subparagraph 3(j)(v) specifically covers information about a current or former officer or employee of a government institution that relates to his or her position or functions, including “the personal opinions or views of the individual given in the course of employment”. ...

Canada, 2021 FCA 88, 2021 D.T.C. 5050 [Kam-Press], this Court considered a similar argument to the argument put forward by the appellant in the case at bar. ...

His counsel objected and, in the course of addressing that objection, repeated an earlier statement before the Tax Court that anything in the Fresh Notice of Appeal should be considered correct. ...

The letter relied upon by the Appellant was mailed to the T1 Processing Review Centre in Shawinigan, Quebec. [31] In brief reasons, by way of a judgment delivered from the bench in McClelland, the FCA considered a situation in which the taxpayer had sent a letter to a CRA Collection Enforcement Officer, as opposed to the Chief of Appeals in a district office or a taxation center, and stated: The Income Tax Act required that a Notice of Objection must be sent to the Chief of Appeals. ...