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Keeping in mind that evidence would be adduced to substantiate the facts, one could imagine situations and circumstances under which a shareholder could be considered as dealing at arm’s length with a corporation and this would render the section inapplicable. ... I would doubt also that the decision in this case would mean that any transaction between a corporation and any shareholder, even though he might own only one share, could be considered as a deal not at arm’s length. ...

In a carefully considered judgment the learned Assistant Chairman of the Income Tax Appeal Board, Mr. ... On the evidence before him he held, however, that for the year 1946 $8,700 should be added to the amount of the assessment and a like amount deducted from that made in the year 1947; for the year 1948 he considered the amount as found by the Board should remain unchanged and, with these variations, dismissed the appeal. ...

At paragraph 3 thereof, this Court considered the following factors: A continuing intention to pursue the appeal; That the appeal has some merit; That no prejudice to the respondent arises from the delay; and That a reasonable explanation for the delay exists. [3] This Court has since slightly reworded and clarified the test: see Canada (Attorney General) v. ... Rafique failed to meet the January 13, 2023 deadline, but submitted a letter to the Court on January 16, 2023 (the next business day) stating that he had attempted to file the record in support of his motion pursuant to Rule 343(3), and requesting that the motion be considered. ...

The appellant took issue with the CRA’s interpretation of section 9 of the Children’s Special Allowance Regulations, SOR/93-12 (Regulations), part of which reads as follows: 9 For the purposes of the Act, a child is considered to be maintained by an applicant in a month if: 9 Pour l’application de la Loi, un enfant est considéré comme étant à la charge du demandeur pour un mois donné si: (a) the applicant, at the end of the month, provides for the child’s care, maintenance, education, training and advancement to a greater extent than any other department, agency or institution or any person; or a) soit le demandeur est à la fin de ce mois celui qui assure le soin, la subsistance, l’éducation, la formation et le perfectionnement de l’enfant dans une plus large mesure que tout autre ministère, organisme ou établissement, ou toute personne; … […] [Emphasis added by the appellant.] ... According to the appellant, a child who is the subject of a child protection measure could be considered as being maintained by his or her parents for the purposes of section 9 of the Regulations if he or she is staying with them on a part-time basis. ...

He argues the decisions are vague and it is unclear what evidence the Minister considered and relied on. [8] Mr. ... Winkler had contravened the Customs Act, the Minister considered whether the terms of release should be varied pursuant to section 133. ...

The Tax Court also expressly considered, among other things, the absence of contracts for the management services, the invoices on which the appellants relied, and the evidence of a bookkeeper. Moreover, first instance courts are presumed to have considered and assessed all of the evidence before them: Mahjoub v. ...

Counsel for the appellant contends that the oral rental agreement between the appellant and Mr Elliot included the use of the buildings from which the appellant received rental income and therefore should be considered as rental assets and not farm assets or alternatively he submits that a portion of the value of the buildings estimated by Mr Woods, a chartered accountant and the appellant’s auditor, as being approximately $7,428.00 should be attributed to the shed used by Mr Elliot and an adjustment made in the amount of recapture of the capital cost allowance. ... Alternatively, counsel for the respondent submits that if the drive shed is to be considered as rental property, the adjustment in the recapture of capital cost allowance should reflect the value of only that part of the shed which was rented to and used by Mr Elliot. ...

Thus, the respondent was entitled to disallow the married exemption claimed by the appellant. 4.2 The Board considered whether an exemption for Louise Di Césare in the amount of $1,492 might not be claimed under paragraph 109(1)(b) in view of the fact that she was wholly dependant upon the taxpayer and lived in the same establishment. ... In the case at bar, the Board is of the opinion that the respondent was justified in allowing the taxpayer to claim for his son Nicolas the exemption for a wholly dependent person set forth in paragraph 109(1)(b). 4.3 The Board also considered whether the appellant was entitled to the child care expenses set forth in section 63 of the new Act. ...

Canada, [1993] 2 F.C. 179 (C.A.) at 187, 47 D.T.C. 5116, it would be considered to be carrying on a business of trading in qualified investments. ... Nonetheless, the appellant submits that the phrase “carries on one or more businesses” in subsection 146.2(6) should be read so that a TFSA trust that carries on a business of trading investments under well-established common law principles should not be considered to carry on a business for purposes of subsection 146.2(6) when the business involves only trading in qualified investments. [13] We find that position untenable. ...

The question, therefore, which we have to determine, 1s, whether the sums paid as rent and by way of royalty, in the circumstances above recited, under options to purchase which have not yet expired, can properly be considered as falling within the language hereinbefore quoted. ... It could be upon the happening of a future contingency only that they would be considered as part of the purchase-money. ...