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In Re Thomas Jackson & Sons Ltd., [1935-37] CTC 162 Dysart, J.—This is an appeal by Thos. Jackson & Sons, Ltd., from a decision of the Municipal Commissioner of Manitoba, on a question of income tax, and involves the interpretation of certain provisions of the Manitoba Income Tax Act, C.A. 1924, c. 91, as amended. ... " " It is hereby agreed on behalf of the above named appellants and His Majesty the King in the right of the Province of Manitoba to make the above statements of facts as and in lieu of evidence upon the hearing of this appeal and that the same may be used and read as evidence upon the hearing of this appeal and for all the purposes thereof.’’ ...

Julius Kayser & Co. Ltd. v. Minister of National Revenue, [1938-39] CTC 334 ANGERS, J. ... Asked if the parent company furnished the appellant with any other services, the witness replied: " " very little. ’ ‘ The advances made to the parent company by the appellant are entered in the latter’s book in a current account in the name of Julius Kayser & Company, New York. It seems to me expedient to cite here a passage from Mutchler's testimony concerning this account: Q. * * * And in that current account Julius Kayser, New York, is credited with the purchase of raw silk made on your behalf? ...

Stinson & Son Ltd. v. Canada (Minister of National Revenue), 2005 FC 1427 Date: 20051024 Docket: T-549-04 Citation: 2005 FC 1427 Ottawa, Ontario, October 24, 2005 PRESENT:      THE HONOURABLE MR. ... STINSON & SON LTD.                                                             and                                                             THE MINISTER OF NATIONAL REVENUE PLACE OF HEARING:                     Montreal, Quebec DATE OF HEARING:                       October 13, 2005 REASONS FOR ORDER:                BEAUDRY J. ...

Stewart & Company Limited v. Minister of National Revenue, [1946] CTC 311 0 ‘CONNOR, J. ... In 1927 see. 10 of this Act read: " 19. On the winding up, discontinuance or reorganization of the business of any incorporated company, the distribution in any form of the property of the company shall be deemed to be the payment of a dividend to the extent that the company has on hand undistributed income.’’ ... Failure to pay the tax within the prescribed time shall render the company liable for interest thereon at that rate of six per centum per annum until paid. ‘ ‘ In 1934 see. 19 was amended by striking out the words "‘in the taxation period 1930 and subsequent periods’’, leaving the section as it stood in 1927. ...

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     ...

The amount awarded in each Court under each of the several heads of damages is set out below: Pecuniary Loss     (a) Cost of Future Care Trial Appellate Division —special equipement $14,200 $14,200 —monthly amount 4,135 1,000 —contingencies 20% 30% —capitalization rate 5% 5% —life expectancy 45 years 45 years   $735,594 $164,200 (b) Loss of Prospective Earnings —level of earnings     $ 830     $1,200 —basic deduction to avoid duplication between the award for future care and that part of the lost earnings that would have been spent on living expenses         440         — Net $390 $1,200 —contingencies 20% 20% —work span 30.81 30.81 —capitalization rate 5% 5% Total $ 59,539 $175,000 Non-Pecuniary Loss     —Pain and Suffering $150,000 $100,000 —Loss of Amenities     —Loss of Expectation of Life     Special Damages $77,344 $77,344   [Page 235] Liability is not an issue. ... Pecuniary Loss   (a) Cost of future care   —special equipment $14,200 —amount for monthly payments (monthly amount $4,135: life expectancy 45 years; contingencies 20%; capitalization rate 7%     557,232   [Page 266] (b) Prospective loss of earnings   (monthly amount $564; work span 30.81 years; contingencies 20%; capitalization rate 7%)   $ 69,981 2. Non-pecuniary Loss   —compensation for physical and mental pain and suffering endured and to be endured, loss of amenities and enjoyment of life, loss of expectation of life       100,000 Total General Damages $741,413 Rounded off at $740,000   To arrive at the total damage award, the special damages of $77,344 must be added to give a final figure of $817,344. ...

Each case stands on its own merits. [5]      In making his decision, the Minister relied on the following assumptions of fact: [TRANSLATION] (a)         The appellant was incorporated on July 1, 1995, as a result of a merger between Groupe Desmarais Inc. and Assurances Pinsonneault, Avard, Paré Inc.; (b)         The appellant's capital stock is distributed as follows:            - Gestion A.C.D. Inc. holds 60% of the voting shares;            - Yvon Pinsonneault holds 20% of the said shares; and            - Martin Avard holds 20% of the said shares; (c)         The capital stock of Gestion A.C.D. ... Watson Appearances Counsel for the Appellant:                             Rock Guertin Counsel for the Respondent:                         Dany Leduc JUDGMENT           The appeal is allowed and the Minister's decision vacated in accordance with the attached Reasons for Judgment. ...

In the Shorter Oxford English Dictionary, 2nd Ed., “political” is defined as ‘‘of, belonging or pertaining to, the state, its government and policy ’ ’ and * " concerned or dealing with politics or the science of government’’. in the same value, "‘subdivision’’ is defined as "‘one of the parts into which a whole is subdivided; part of a part; a section resulting from a further division’’. ... The government, conduct, management and control of the University and of University College, and of the property, revenues, business and affairs thereof, shall be vested in the Board. ‘ ‘ Exhibit 1 is The University Act, R.S.O. 1937, ¢. 372. ... In considering the powers of that Board, Lord Haldane said: " " They are a body with discretionary powers of their own. ...

& M. WOOD PRODUCTS (1985) LTD., Appellant, and HER MAJESTY THE QUEEN, Respondent. ... & M. Wood Products (1985) Ltd. Forest Management License Agreement, transcript of John Kennedy Davies and related undertakings, and financial statements for L & M Wood Products (1985) Ltd. Preparation of quantitative schedules from the                                              5 hours undertakings, including Schedule of Reforestation Costs, Schedule of Road Construction, Schedule of Volumes Harvested, Schedule of Areas Harvested, and Schedule of Dues Analysis and reconciliation of data provided regarding                12 hours the Renewal Fund in the accountant's working papers, Statement of Activity, financial statements, ledger cards and bank records for 1987 to 1990 Preparation of Evidence                                                                       36 hours Review of Evidence and background documents in                       8 hours preparation for Trial                                                                                             ________ Time spent by Kathryn Holgate                                                         109 hours                                                                                                                                 @$130 $14,170 Partner Consultation, Review of Evidence                                       9.5 hours                                                                                                                                                 @$200 $ 1,900                                                                                                                                                                                 $16,070 [12]          In the case of Chrystal Ann Quintal et al. v. ...