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Moreover, I do not accept the explanations provided by the appellant and her spouse with regard to the existence of a relationship of subordination; I believe that they have distorted reality. [41]          Unemployment insurance is a social program established to help those who really lose their jobs, whether temporarily or permanently; there must be genuine employment and a genuine layoff, since unemployment insurance is not a financial support program to help small businesses develop. [42]          The work the appellant did for the payer during the periods at issue did not meet the requirements and criteria which, under the Act and according to the case law, must be met in order for employment to be considered as being held pursuant to a contract of service. [43]          For these reasons, the appeals are dismissed. ...

He did not consider all of the factors he should have considered, nor did he assess the context fully. ...

More specifically, what must be determined is whether the reference in section 84.1 of the Act to subsection 186(4) of the Act, dealing with when one corporation is controlled by another and thus connected, must also be considered as referring to subsection 186(2) which contains a definition for purposes of Part IV tax and extends the normal meaning of control. [3] The appeal was presented on the basis of a Statement of Agreed Facts and an Agreed Combined Book of Documents. ...

Total payroll expenses for 52 weeks must be considered. [6] Counsel for the appellant first referred to the Supreme Court of Canada's decision in Canderel Ltd. v. ...

This is unlikely, given that the letter accompanying the cheque was delivered by mail that same day, that the letter had to have been transferred from the mail room to a Registry officer and that the Registry left the appellant a telephone message regarding the cheque on May 7, 2013. [39]         There are other events that must also be considered. [40]         On May 30, 2013, the Registry wrote to the appellant regarding the respondent's May 7, 2013, motion. ...

Yet, it is not uncommon that what might be considered enthusiastic representation by one side is viewed as “inexplicable”, a lack of “professional decency”, “shocking”, “lack of good faith”, here by the Appellant in describing the Respondent’s behaviour in his written submissions on costs. [20]         The Appellant raises these concerns pointing specifically to four actions by the Respondent: a. ...

Step 4 simply makes it clear that the fact that a taxpayer did not actually receive the Notice of Assessment is irrelevant. [4]              In Mpamugo, I concluded that the taxpayer’s credibility is to be considered in Step 2 rather than in Step 1. ...

By letter dated January 2, 2013, the Minister informed Eva that her application was allowed and that her notice of objection was considered to have been filed on the date of that letter which was sent to Eva at the following address: 153 Saint Lucie Dr., North York, Ontario, M9M 1T4. [4]              The Minister reassessed Maria’s and Mohan’s 2010 taxation year by notices of reassessment dated August 14, 2014. [5]              By letter dated July 25, 2014 sent by Xpresspost to Eva Roopchand at 37 Little Drive, Scarborough, Ontario, M1B 1Y6, the Minister confirmed the reassessment of her 2010 taxation year and the gross negligence penalty imposed pursuant to paragraph 163(2) of the Act. ...

He held that the property could not be considered as inventory, as the appellant was not in the business of buying and selling houses. ...

As there is no tax payable, we have not considered them under the VDP. ...