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Highweb & Page Group Inc. v. The Queen, 2015 TCC 137 (Informal Procedure) Docket: 2014-1703(IT)I BETWEEN: HIGHWEB & PAGE GROUP INC., Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... Introduction and Issues [1]              The Appellant, Highweb & Page Group Inc. ... Her Majesty The Queen, 2006 TCC 597 (“ Zeuter Development ”) at paragraph 26. ...

The 44 workers concerned are as follows: Audy, Michel                                                  Lampron, Sylvain Béland, Michel                                                                Ledoux, Francis Benoit, Claude                                                                 Leduc, Benoit Blanchard, Claude                                                           Lévesque, Alain Blanchette, François                                       McCraw, Kim Bonneville, Marcel                                                          McLaughlin, Sylvie Bourassa, Mario                                                              Martineau, Serge Brien, Mathieu                                                                 Meunier, Claude Charron, Martin                                                               Migneault (Mignot), Julie Chartrand, Jacques                                                         Moisan, Hélène Cornescu, Horia                                                              Nicolas, Michel Desmarais, Richard                                         Pérusse, Gabriel Dion, Joane                                                      Pilon, Martin Doré, Daniel                                                     Proulx, Eddy Dufour, André                                                                 Provencher, Marc Forget, Normand                                                             Rhéaume, Bruno Gadoua, Pierre                                                                 St-Jean, Daniel Hébert, Denis                                                   Tanguay, François Hudon, Julie                                                     Tessier, Jenny Jacob, Lyne                                                      Vachon, Jean-Pierre Laliberté, Guy                                                  Vanier, Luc Lamontagne, René                                                          Vanier, Pierre [3]            In reaching his decision in this case, the Minister relied in particular on the following assumptions of fact, of which the appellant company either admitted or denied the truth:                                 [TRANSLATION] (a)            The appellant is a company that produces children's television programs. ... He added that he did not construct any sets in 1998. [90]          Mr. ... and The Minister of National Revenue PLACE OF HEARING:                                         Montréal, Quebec DATES OF HEARING:                                         November 19, 20, 21, 22 and 23, 2001 REASONS FOR JUDGMENT BY:      The Honourable Judge François Angers DATE OF JUDGMENT:                                       November 6, 2002 APPEARANCES: For the Appellants:                                               Roch Guertin For the Respondent:                             Stéphane Arcelin                 For the Intervener:                                                The Intervener himself COUNSEL OF RECORD: For the Appellants:                                 Name:                      Roch Guertin Firm:                                        Montréal, Quebec For the Respondent:                             Morris Rosenberg                                                                                                 Deputy Attorney General of Canada                                                                                 Ottawa, Canada 2000-3683(EI) BETWEEN: LES PRODUCTIONS PETIT BONHOMME INC., Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent. ...

(Transcript: pages 63 & 64) Q. Do you recall when — now you said I think sometime in 1979 — the first of these leases was entered into sometime in 1979? ... Interest rates will be charged as follows: Trennd — operating — at the bank’s minimum lending rate (MLR) + 1 per cent — special — MLR+2 2 per cent Pioneer — capital — MLR + 11/2 per cent Allied — capital — MLR + 11/2 per cent — interim — MLR + 2 per cent Cal-Gas — capital — MLR + 11/2 per cent CIBC also advised that it would review this line of credit on or about September 30, 1981. ... The plaintiff still argues that the true purpose of the $1.7 million borrowing on a proper view of the transaction — truly the transactions — and the Court views them back to summer 1978 — was to provide a credit facility for Cal-Gas. ...

Brian & Deborah Dewan Enterprises Ltd. v. The Queen, 2017 TCC 135 (Informal Procedure) Docket: 2016-5262(GST)I BETWEEN: BRIAN & DEBORAH DEWAN ENTERPRISES LTD., Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... “Johanne D’Auray” D’Auray J.   Citation: 2017 TCC 135 Date: 20170719 Docket: 2016-5262(GST)I BETWEEN: BRIAN & DEBORAH DEWAN ENTERPRISES LTD., Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... The appellant did not collect and remit GST/HST on the sales of the limousines, which amounted to $13,741.00. [3]              In this appeal, the provision applicable is section 141.1 of the Excise Tax Act (“ Act ”). ...

As a result, the employment of each worker was insurable employment for the purposes of the Act. [3]   In making his decisions, the Minister considered the following facts in paragraph 16 of the Reply to the Notice of Appeal: (a) the appellant is an incorporated entity; (b) the appellant operates a PVC window and door sale and manufacturing business; (c) during the period at issue, 9073-3965 Québec Inc. held and controlled all of the appellant’s voting shares; (d) during the period at issue, Josée Bilodeau held and controlled all the voting shares of 9073‑3965 Québec Inc.; (e) Josée Bilodeau is the mother of the workers; (f) the appellant had six directors responsible for: (i) Sales; (ii) Field sales; (iii) The two factories; (iv) Purchasing; (v) Shipping; and (vi) Human Resources; (g) Bianca Dupuis was the Purchasing Director; (h) Bianca Dupuis looked after: (i) sales customer service; (ii)   price changes; (iii)   marketing brochures; and (iv)   the computer system; (i) Catherine Dupuis was Director of Human Resources; (j) Catherine Dupuis looked after: (i) hiring and terminations; (ii)   employee complaints; (iii)   training; (iv)   health and safety; and (v)   social events; (k)   Jonathan Dupuis was the Director of the appellants’ two factories; (l)   Jonathan Dupuis looked after: (i)   purchasing machinery and trucks; (ii)   product research and development; (iii)   supervising team leaders; and (iv)   replacing missing staff; (m)   Samuel Dupuis was: (i)   a day labourer until August 2016; then (ii)   replacement team leader since August 2016; (n)   As a day labourer, Samuel Dupuis worked on the door and window assembly line; (o)   As a replacement team leader, Samuel Dupuis supervised 10 to 15 employees working in one of the appellant’s two factories; (p)   the appellant remunerated the workers by direct deposit for services rendered; (q)   the appellant made deductions at source from the workers’ pay; (r)   the workers met regularly with Josée Bilodeau to discuss work; (s)   the appellant retained her right of supervision; (t)   the appellant issued T4 slips to the workers; (u)   the workers were paid at different hourly rates depending on their position and seniority; (v)   workers were paid overtime when they worked more than 40 hours a week; (w)   during part of the period at issue, Jonathan Dupuis was paid a fixed weekly salary; (x)   while Jonathan Dupuis was paid a fixed weekly salary, the additional hours he worked were banked and converted to leave; (y)   the appellant paid the workers annual bonuses because they performed additional duties; (z)   with the bonuses they received, the workers’ salaries were in line with the market average; (aa)   the workers had not completed post-secondary studies; (bb)   the workers gained experience over the years, working for the appellant; (cc)   the workers completed timesheets, as did the other employees working for the appellant; (dd)   the workers were covered by the appellant’s group insurance, as were the other employees working for the appellant; (ee)   the workers accrued vacation days based on their seniority; (ff)   the workers worked for the appellant full-time for several years; (gg)   as experienced, reliable and responsible workers, they had a somewhat flexible work schedule; (hh)   as persons working in management positions, the workers worked a few hours without asking for remuneration; (ii)   the workers mostly worked in the appellant’s place of business; (jj)   as workers in management positions and/or workers who did not have to use heavy equipment, they worked a little from home; (kk)   the appellant paid for certain expenses when the workers worked outside the area; (ll)   the appellant operated year‑round; (mm)   the workers were hired year‑round; (nn)   the duties performed by the workers were essential to the appellant’s activities; and (oo)   none of the workers received extravagant or overly generous terms of employment, based on their position in the company. [4]   At the hearing, the agent for the appellant admitted that a contract of service existed between the appellant and each worker. ... CITATION: 2019 TCC 96 DOCKET: 2017-4148(EI) STYLE OF CAUSE: PORTES & FENÊTRES ABRITEK INC. ... Drouin Deputy Attorney General of Canada Ottawa, Canada     ...

Diner" Judge FEDERAL COURT SOLICITORS OF RECORD DOCKET: T-812-15   STYLE OF CAUSE: R & S INDUSTRIES INC v MINISTER OF NATIONAL REVENUE   PLACE OF HEARING: Edmonton, Alberta   DATE OF HEARING: January 20, 2016   JUDGMENT AND REASONS: DINER J.   DATED: MARCH 2, 2016   APPEARANCES: Darryl Antel   For The Applicant   Donna Tomljanovic   FOR THE RESPONDENT SOLICITORS OF RECORD: Moodys Gartner Tax Law LLP Edmonton, Alberta   For The Applicant   William F. Pentney Deputy Attorney General of Canada Edmonton, Alberta   For The RESPONDENT     ...

D & J Driveway Inc. v. Canada (Minister of National Revenue), 2003 FCA 453 Date: 20031127 Docket: A-512-02 Citation: 2003 FCA 453 CORAM:       DÉCARY J.A. ... Tr., LL.L.                                                   FEDERAL COURT OF APPEAL                                                       SOLICITORS OF RECORD FILE:                                                                              A-512-02 STYLE OF CAUSE:                                                      D & J DRIVEWAY v. ... REASONS FOR JUDGMENT OF THE COURT:     LÉTOURNEAU J.A. DATE OF REASONS:                                                  NOVEMBER 27, 2003 APPEARANCES: Lyne Thériault and Marie-Hélène Montminy                      FOR THE APPLICANT Martin Gentile and Alain Gareau                                       FOR THE RESPONDENT SOLICITORS OF RECORD: Pouliot, L'Écuyer                                                              FOR THE APPLICANT Sainte-Foy, Quebec Department of Justice- Canada                                        FOR THE RESPONDENT Montréal, Quebec ...

Eli Lilly & Co. Ltd. v. Minister of National Revenue, [1955] S.C.R. 745 Supreme Court of Canada Eli Lilly & Co. ... Ford & Co. Ltd. v. Commssr. of Inland Revenue, 12 T.C., 997 at 1004, applied. ... CR. 269. 2   [1953] Ex. CR. 269. 3   (1932) 16 T.C. 570. 4   (1926) 12 T.C. 997. 5   12 T.C. 768. 6   12 T.C. 927. 7   (1951) 32 T.C. 133 at 155. 8   (1939) 63 C.L.R. 382. 9   (1930) 16 T.C. 570. 1 0  (1932) 16 T.C. 570. ...

& D. H. Holdings Limited v. Minister of National Revenue, [1986] 2 CTC 2364, 86 DTC 1730 Taylor, T.C.J. ... This amount was calculated by the Respondent as follows: Milk Quotas Other Assets Total Total Proceeds $1,600,000.00 $1,094,700.00 $2,694,700.00 Adjusted Cost Base 1,000,000.00 515,000.00 1,515,000.00 Excess $ 600,000.00 $ 579,700.00 $1,179,700.00 Section 14 — Proceeds (12) $ 300,000.00 $ 289,850.00 $ 589,850.00 Milk Quotas Other Assets Total Total Opening Balance Accumulative Eligible Capital $ 1,579.00 Nil $ 1,579.00 Revised Negative Accumulative Eligible Capital $ 298,421.00 $ 289,850.00_$_ 588,271.00 Deduct: Amount reported Nil $ 289,850.00 $ 289,850.00 Increase reassessment $ 298,421.00 Nil $ 298,421.00 (cc) the Appellant acquired shares of Robbinex Trading Corporation (hereinafter 'Robinex’) from its parent company’s shareholders for $700,000 on or about January 1, 1981. ... The butter might be stored on the premises of the appellant — at the option of the C.D.C. — but that in no way altered this elementary situation. ...

Western Leaseholds & Western Minerals v. Minister of National Revenue, [1958] CTC 257, 58 DTC 1128 CAMERON, J. ... A.— Loans. ’ ’ Then as a result of undertakings given at the examination for discovery to produce further information, Mr. ... By a letter-agreement dated December 31, 1947 (Exhibit 19) between Minerals and Leaseholds, it was agreed that Leaseholds should retain the $250,000 option money paid by Imperial and that in respect of the Imperial agreement, Minerals would grant to Leaseholds an exclusive option to purchase from time to time up to 7 per cent of its royalty on the following basis: Per acre On the first 10,000 acres $2.63 for each 1% purchased '' 66 second 7 “ PA 10 é¢ “ “ ‘ ‘ [ar 4 third [ar {C 1.58 '' [4 H “ ** balance of acreage 1.05 “ “ “ The only clear evidence relating to these payments of $34,850.18 and $199,544.55 is found in a paragraph of Exhibit 32—an agreement between Minerals and Leaseholds dated December 30, 1950, and called ‘‘An Agreement of Settlement and Adjustments’’. ...