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What is required is a clear and settled intention to occupy the premises as a “primary place of residence”, considered in the context of an individual’s personal, family and work related circumstances. ...

This finding is not central to the Decision, and the Applicant offers no explanation for why it was allegedly unreasonable. [34]   The Applicant also argues that the Minister considered irrelevant factors, namely news releases issued by the CRA, as well as a blank standard form agreement employed by Fiscal Arbitrators. ...

This finding is not central to the Decision, and the Applicant offers no explanation for why it was allegedly unreasonable. [34]   The Applicant also argues that the Minister considered irrelevant factors, namely news releases issued by the CRA, as well as a blank standard form agreement employed by Fiscal Arbitrators. ...

They noted that during this time she and her husband secured an apartment, she began attending school to learn English, she obtained a driver’s licence and she had a child. [13]     The Citizenship Judge then considered whether the Applicant maintained residence in Canada. ...

She explained in her working paper that “since the company paid the employees both the daily flat rate allowance and a per-kilometre rate allowance paid to the employees for the same day of work (same use), all amounts paid are considered unreasonalbe[sic] allowance and are taxable.” ...

Both provided submissions which have been where necessary considered by the Court for the purposes of these reasons.   ...

Whitney, 2002 FCA 266, the Federal Court of Appeal (FCA) considered whether compensation received by a New Brunswick government employee, while unable to work by reason of a work-related injury, came within the ambits of the aforementioned para. 56(1)(v) and subpara. 110(1)(f)(ii). ...

This, again, supports the conclusion that the Appellant never had a settled intention at any point in time to treat the Aurora property as his primary and permanent place of residence. [34]   Nor can it be considered a secondary residence in my opinion in respect to the Appellant's circumstances. ...

In his analysis of each of the first three situations, the Assistant Commissioner considered Ms.  ...

These reassessments were confirmed by the Minister of National Revenue (the “Minister”) on May 16, 2016, and the application for an order extending the time is dated October 24, 2018, or 29 months later. [2]   The Minister opposes this request. [3]   The Court considered the following essential facts: a)   On July 21, 2011, the Minister issued a notice of assessment for the 2009 taxation year. ...