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Astro Consulting also argued that it may reasonably be considered that one of the main reasons for the separate existence of Astro Consulting and Lanmark Holdings / Lanmark Engineering was to reduce taxes payable under the Act and, therefore, Astro Consulting would be associated with Lanmark Holdings and Lanmark Engineering as a result of the application of subsection 256(2.1) of the Act. [7] The Tax Court Judge rejected Astro Consulting’s arguments and found that it was not associated with Lanmark Holdings or Lanmark Engineering. ... Rather, the reason for the separate existence of the corporations as stated by Aaron Glazier (the sole witness at the Tax Court hearing) was a factor that the Tax Court Judge considered. [9] Astro Consulting will only be associated with Lanmark Holdings and Lanmark Engineering under subsection 256(2.1) of the Act if it may reasonably be considered that one of the main reasons for their separate existence in a taxation year is to reduce the amount of taxes payable under the Act. [10] Astro Consulting argued that having the separate corporations allowed Astro Consulting to split its income between its two shareholders by paying dividends. ...

According to the applicant, the officer should have considered her new notice of assessment that resulted from the amended income tax return for the 2019 taxation year. ... Moreover, in the context of an application for judicial review, it is not for this Court to reweigh or reassess the evidence considered by the decision maker (Vavilov at para 125; Clark v Air Line Pilots Association, 2022 FCA 217 at para 9). ... The respondent argues that the CRA was entitled to request information it considered relevant to the determination of the applicant’s admissibility. ...

The facts that are not in dispute are as follows: (1) the respondent alleges that the Class A common shares (‘‘Class A shares”) of the share capital of Télé-Capitale Ltée (“TCP”) had an adjusted cost base of $7 on December 31, 1971, whereas the appel- lants maintain that the adjusted cost base of the Class A shares was $8.40 on that date; (2) on December 31, 1971, the authorized and issued common share capital of TCP consisted of 5,000 Class A common shares and 5,000 Class B common shares having a par value of $5 each, distributed as follows: Holder Class A shares Class B shares Jevlam Inc 1,000 600 Canadian Cablesystems Limited 2,000 CHRC Limitée 2,000 1,200 CKCV (Québec) Limitée 2,000 1,200 (3) since the Class A shares which are the subject of the dispute had been subdivided before they were disposed of, for purposes of valuation the supplementary letters dated April 13, 1972 should be treated as applying at December 31, 1971, so that a Class A common share, or equally, a Class B common share, having a par value of $5 would be converted and subdivided into 190.8125 Class A common shares and 22.1875 Class B common shares having no par value; (4) Class A and Class B shares are considered to be of the same value by the appellants and the respondents; (5) on December 31, 1971, TCP did not own any subsidiaries; (6) on September 1, 1972, TCP purchased all the shares of CHRC Limitée, Radio Laval Inc and Hardy, Radio & Television Ltd. ... After studying and analysing the facts contained in these two tables, we can conclude that Télé-Capitale Ltée is a company in a very good financial position, in which the estimated earnings of $0.54 per share on December 31, 1971 could be considered to be maintainable. ... On the other hand the comparative tables provided by the respondent’s assessor clearly indicate that a multiplier of between 8.9 and 11 would be realistic, and that estimated earnings of $0.54 per share on December 31, 1971 could be considered maintainable. ...

Each case must be considered on its own facts. The lobster traps were capital property, being in the nature of fixed capital rather than circulating capital. ... If the thing is a ship or a jetty which is ordinarily used for the purpose of earning profits, the fact of its profitability is an element to be considered in assessing its capital value. ... Where, however, there is only a partial injury, as there was in the present case, there are necessarily two elements to be considered if the owner is to be put back, so far as money can do it, in the same position he would have been but for the tortfeasor’s wrongdoing. ...

On the first issue, he stated that the amount should be treated as a shareholder loan of Larry York to Park Mobile and consequently, it should be considered as an asset carried over from Trojan to Park Mobile because the amount was used to develop the site by Trojan. ... In short, Mr York and the purchaser of 50% of the shares in Park Mobile considered the amount of $75,834.27 as belonging to park Mobile by virtue of Larry York placing the amount into the said company. In the alternative, counsel submits that it should be considered as a capital loss. ...

A deteriorated house and barn were considered of little or no value. Elmwood Drive runs from the centre of the city in a northerly direction. ... The respondent's expert viewed the property as very rural in nature, not to be compared with active residential development to the south of the TransCanada Highway and to be considered without sewer or water services. ... Having considered all of the evidence as to value, I have come to the conclusion that the appellants have over stated and the respondent under stated the value. ...

However, I find compelling the Applicants’ position, emphasized in their reply submissions, that CRA appears to have considered the relevant statutory authority to have been sufficient to authorize a reassessment of Strike’s income tax return for the 2017 taxation year (a year in which the Applicants submit the reassessment was favourable to CRA). ... Conclusion [21] The last two factors considered above favour granting the Applicants’ motions. ... While the Applicants’ case for an extension of time is not overwhelming, having considered the relevant factors together and taking into account the principle that the overriding consideration is that the best interests of justice be served, I am satisfied that extensions of time are warranted in the three proposed applications. [22] As such, my Order will grant the Applicants’ motions and afford each of the Applicants an extension of time to 30 days from the date of the Order to commence its application for judicial review. ...

These deductions are part of the purchase price of the grain which must be accounted for in full and paid into the hands of the grower at the proper time, and it could not in any case be considered a profit or gain to the Association. ... What might have been the subject of taxation would be the commission charged by the broker, which could be considered as part of his own income; as it is here the case with respect to the officers and employees of the Association; but it could in no case be considered a gain or profit of the Association and much less subject to taxation, as it could by no means be construed as its income. ...

Legal framework [4] Subsection 147(3) of the Tax Court of Canada Rules (General Procedure) sets out the factors which may be considered by this Court in determining costs. In this instance, no expert witnesses testified so the relevant factors are as follows: the result of the proceeding; the amounts in issue; the importance of the issues; any offer of settlement made in writing; the volume of work; the complexity of the issues; the conduct of any party that tended to shorten or to lengthen unnecessarily the duration of the proceeding; the denial or the neglect or refusal of any party to admit anything that should have been admitted; whether any stage in the proceedings was i) improper, vexatious, or unnecessary, or ii) taken through negligence, mistake or excessive caution; and any other matter relevant to the question of costs. [5] Some key principles for determining a costs award include the following: the Court has broad discretion which must be exercised on a principled basis and not arbitrarily; [3] none of the factors in subsection 147(3) are determinative and all relevant factors should be considered; [4] costs are intended to be compensatory and contributory rather than punitive or extravagant, with the proper question being what the losing party’s appropriate contribution to the successful party’s costs should be; [5] a lump sum may be awarded after considering the amounts at issue, the complexity and importance of those issues, the work generated, and a party’s success; [6] there must be egregious circumstances for the court to consider awarding solicitor-client costs, which remain discretionary; [7] increased (partial indemnity) costs generally vary between 50 to 75 percent of solicitor-costs [8] but it is not settled law; [9] and exceptional circumstances are not needed for a costs award above the tariff. [10] Analysis and discussion (a) The result of the proceeding [6] The appellant was wholly successful in that I found the unreported income should not have been attributed to him and as a result, he was also not grossly negligent. ... (b) The amounts in issue [8] The significance of the amounts in issue must be considered contextually and in relative terms. [11] In this instance, the amounts might have been significant to the appellant but they are not significant in the context of appeals before this court. [9] Therefore, this factor is neutral. ...

REASONS FOR JUDGMENT Spiro J. [1] Unless the written agreement or court order under which support payments are receivable identifies an amount of support as being solely for the support of a recipient who is a spouse or former spouse (or their common-law equivalents), each support payment made under the written agreement or court order by the parent of a child is considered a child support payment and is, therefore, not deductible by the payer and not taxable to the recipient under the Income Tax Act (the “Act”). [1] [2] The facts in this appeal are simple. ... Vohra argued that the $3,500 per month he paid in 2018 – for a total of $42,000 – should still be considered spousal support paid under the Separation Agreement notwithstanding the termination provision. [4] [5] My colleague, Justice MacPhee, considered Dr. ...