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If the framers of the Regulation had intended to mean the business itself, they would have used the word " thereby " or " by it " rather than the word " therein ", which latter word conveys the sense of being inside something physical. In the same vein the word " therein " can hardly apply to personnel. ... " is a hairdressing salon operating in the City of Edmonton ". ...

Tusket Sales & Service Limited v. The Queen, docket 1999-5124(GST)I (Informal Procedure) Date: 20000727 Docket: 1999-5124-GST-I BETWEEN: TUSKET SALES & SERVICE LIMITED, Appellant, and HER MAJESTY THE QUEEN, Respondent. Reasons for Judgment Hamlyn, J.T.C.C. [1]            This is an appeal with respect to an assessment under Part IX of the Excise Tax Act (the " Act ") for the period January 1, 1993 to February 29, 1996, by Notice of Assessment No. 01CB0202152 dated July 17, 1996. [2]            The Appellant is a corporation involved in the sale of new and used motor vehicles. [3]            Between 1994 and 1995, the Appellant sold 14 vehicles to one Vaughn Pictou ("Pictou"), a status Indian. ... Pictou indicating that GST was paid; 6(i)           at no time did Mr. ...

Dow & Duggan Log Homes International (1993) Limited v. The Queen, 2019 TCC 280 Docket: 2017-2928(GST)G BETWEEN: DOW & DUGGAN LOG HOMES INTERNATIONAL (1993) LIMITED, and HER MAJESTY THE QUEEN, Respondent.   ... Factual background – Deposits and work-in-progress [59]   With respect to work-in-progress, Mr. ... Drouin Deputy Attorney General of Canada Ottawa, Canada     ...

Paragraph 12 refers to — and I quote — Lou Lokash Limited received a benefit or advantage in the amount of $50,000 from Lou Lokash & Associates Limited which amount is included in computing the income of Lou Lokash Limited, a shareholder, pursuant to subsection 15.1 of the Income Tax Act. ... They had only the word of Lou Lokash that they held a proportionate interest in such a mortgage — indirectly through the corporation Lou Lokash & Associates, but they held nothing directly in the mortgage as such. ... What they had was simply their confidence in the organization “Lou Lokash & Associates” — in fact in Lou Lakash personally, if one would care to put it on that basis. ...

& 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. ...

Dock Edge + Inc. v. The Queen, 2019 TCC 11 Docket: 2016-539(IT)G BETWEEN: DOCK EDGE + INC., Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... Russell” Russell J.   Citation: 2019TCC11 Date: 20190116 Docket: 2016-539(IT)G BETWEEN: DOCK EDGE + INC., Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... Drouin Deputy Attorney General of Canada Ottawa, Canada     ...

BUREAU BARRISTER & SOLICITOR INCORPORATED, Applicant, and HER MAJESTY THE QUEEN, Respondent.   ... Except as otherwise indicated, statutory references herein are provisions of the ETA. [2]   Under the marginal heading, “When order to be made”, subsection 305(5) provides: (5)   No order shall be made under this section unless (a)   the application is made within one year after the expiration of the time otherwise limited by this Part for appealing; and (b)   the person demonstrates that (i)   within the time otherwise limited by this Part for appealing, (A)   the person was unable to act or to give a mandate to act in the person’s name, or (B)   the person had a bona fide intention to appeal, (ii)   given the reasons set out in the application and the circumstances of the case, it would be just and equitable to grant the application, (iii)   the application was made as soon as circumstances permitted it to be made, and (iv)   there are reasonable grounds for appealing from the assessment. [3]   The respondent asserts that the following four requirements specified in subsection 305(5) were unmet: subparagraph 305(5)(b)(i) – the applicant must demonstrate that within the 90-day period for appealing … it had a bona fide intention to appeal; subparagraph 305(5)(b)(ii) – given the reasons set out in the application and the circumstances of the case, it would be just and equitable to grant the application; subparagraph 305(5)(b)(iii) – the application was made as soon as circumstances permitted; and subparagraph 305(5)(b)(iv) – there are reasonable grounds for appealing … Factual overview: [4]   At the hearing, an amended affidavit of Canada Revenue Agency (CRA) officer S.  ... Drouin Deputy Attorney General of Canada Ottawa, Canada     ...

Rip" J.T.C.C. [1]               85 DTC 568. [2]               [1971] Tax A.B.C. 717, 71 DTC 476. [3]               66 DTC 714, 42 Tax A.B.C. 174. [4]               Paragraph 18(1)(a) of the Act. [5]               Section 67 of the Act. [6]               R.S.C. 1927, c. 97. ... Electric, supra at 1028. [23]             (1957), 57 DTC 1055 at 1062. [24]             (1947), 3 DTC 1090. [25]             Edwin C. ... In any event Iacobucci J. rejected that argument. [27]             [1988] 2 S.C.R. 175 at 189. [28]             Symes, supra at 6014. [29]             Ibid. [30]             See R. v. ...

& F. and Sumas, dated April 16, 1981. Exhibit A-6 — Form letter from M. ... & F. The "distribution rights’ applied to a larger area — all of Canada — and indeed export markets (see Exhibit A-5). ... & F., so that M. & F. had no further involvement with that company. ...

Trew Security & Communication Ltd. v. M.N.R., docket 97-1887-UI Date: 19991026 Dockets: 97-1887-UI; 97-195-CPP; 97-2084-UI; 97-218-CPP; 97-2085-UI; 97-219-CPP; BETWEEN: TREW SECURITY AND COMMUNICATIONS LTD., PATRICIA WALLACE, DOUGLAS WALLACE, Appellants, and THE MINISTER OF NATIONAL REVENUE, Respondent, Reasons for Judgment MacLatchy, D.J.T.C.C. [1] These appeals were heard on common evidence at Toronto, Ontario on July 8, 1999. [2] The opening statements of these appeals clarified the positions of the parties. [3] The Respondent conceded that the appeals filed by Douglas Wallace and Patricia Wallace for unemployment insurance purposes should be allowed as both Douglas and Patricia Wallace were at all relevant times owners and each controlled more than 40% of the voting shares of Trew Security and Communications Ltd., the Payor. The Appellants were not engaged in insurable employment within the meaning of the Unemployment Insurance Act (the " Act ") and Employment Insurance Act (the " Amended Act ") for the 1995 taxation year as each Appellant controlled more than 40% of the voting shares of the Payor with the result that the employment was excepted by paragraph 3(2)(d) of the Act and paragraph 5(2)(b) of the Amended Act. [4] No amount of the unemployment insurance premiums or employment insurance premiums assessed the Payor relate to the employment of either Patricia or Douglas Wallace as it was determined above that their employment with the Payor during both 1995 and 1996 taxation years was not insurable employment. [5] The Payor applied to the Respondent for reconsideration of the assessments of October 16, 1996. [6] By letter dated September 10, 1997, the Respondent informed the Payor that it had been determined that the Payor's workers (Robbie Robert Wallace and Wayne Hilts) were employed pursuant to a contract of service and, accordingly, the Respondent confirmed the assessments of October 16, 1996. [7] In making his decision, the Respondent relied on the following facts set out in paragraph 11 of the Amended Reply to the Notice of Appeal in the case of Trew Security and Communications Ltd. (97-1887(UI)): "(a) the Appellant is an incorporated business of which, at all material times, Douglas Wallace and Patricia Wallace were shareholders; (b) Patricia and Douglas Wallace are married to each other; (c) the Appellant operates a small service business involved in the installation of burglar and fire alarms, central vac, television and telephone systems and intercoms in personal residences; (d) during the 1995 taxation year, Patricia and Douglas Wallace were severally paid by cheque the amount of $36,000.00 as management fees; (e) at all relevant times, Douglas Wallace owned and controlled more than 40% of the voting shares of the Appellant; (f) the Appellant engaged Robbie Wallace and Wayne Hilts as workers (the "Workers"); (g) the Workers were employed by the Appellant pursuant to contracts of service. ... Although called a "management fee", such payment really constituted pensionable employment and within the meaning of subsection 27(5) and paragraph 6(1)(a) of the Canada Pension Plan (the " Plan ") as amended. ...