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During the 1966 to 1972 taxation years Marquis Ltée and Beaudet & Fils Inc (hereinafter “Beaudet Inc”) founded and operated a company known as Beaudet & Marquis Enrg, which became Beaudet & Marquis Inc on January 1, 1973; 4. ... Re Beaudet & Fils Inc (“Beaudet Inc”) 2. During the 1969 to 1972 taxation years the applicant was involved in the construction field; 3. During the 1966 to 1972 taxation years Marquis Ltée and Beaudet Inc founded and operated a company known as Beaudet & Marquis Enrg, which became Beaudet & Marquis Inc on January 1, 1973; 4. ...

Now to do this, once again, we are talking of 1,200 to 1,400 employees, so for us — the practical aspect — the approach — the easiest and most practical possible — was to use the already existing systems, the Admiral company’s payroll system; and by using this system former Admiral employees were able to tell us — to give us information on amounts owed to each employee for services rendered up to November 4. ... Act — case law — analysis 4.01 Act The main provisions of the Income Tax Act, R.S.C. 1952, c. 148 (am. ... Coopers & Lybrand Ltd. (4.02(22)). In fact, 55 of Admiral's employees at Cambridge, Ontario sued Coopers & Lybrand Ltd. ...

Shultup Management & Investments LTD v. Minister of National Revenue, [1972] CTC 2655 The Chairman (orally):—This is an appeal by Shultup Management & Investments Ltd, a company incorporated under the laws of the Province of British Columbia, against a Notice of Reassessment by the Minister for the taxation year 1962. ... Zielinski went to the specified location and staked the area of the old workings, and continued on to stake a total of 14 claims, during the course of which assignment he managed to personify the classical mind’s-eye picture of a prospector chipping away at outcroppings and deciding by “an eyeball assessment” — a talent gained through years of experience — whether or not a particular area was worthy of staking and recording or not. ... I have read the evidence in great detail, and I find nothing in the line of fact that would allow me to infer that the appellant company was the person who made the arrangement — or the corporation that made the arrangement — with Cohen as contemplated by subsection 83(3). ...

They may be summarized as follows: — between March 24, 1992 and February 1, 1993, the respondent imported air diffusers into Canada; — the imported air diffusers were made of plastic and were designed as an attachment to hair dryers; — at the time of each importation, the air diffusers were classified under Tariff item No. 3926.90.90 of Schedule I to the Customs Tariff [3] as “other articles of plastics”; — the respondent urged that the air diffusers should be classified under Tariff item No. 8516.31.10 as parts of domestic hair dryers and therefore requested, pursuant to paragraph 60(l)(b) of the Customs Act, a re-determination of the tariff classification of the air diffusers. It was determined that the imported goods were properly classified under Tariff item No. 3926.90.90 as other articles of plastics; — the respondent subsequently requested a further re-determination of the tariff classification of the air diffusers by the Deputy Minister of National Revenue for Customs and Excise pursuant to paragraph 63(l)(a) of the Customs Act; — on August 26, 1993, the appellant confirmed the classification of the air diffusers under Tariff item No. 3926.90.90; — on September 15, 1993, the respondent appealed the decision to the Tribunal pursuant to section 67 of the Customs Act; — by the decision here under appeal, the Tribunal found in favour of the respondent; — the parties are in agreement that the classification of goods under Schedule I to the Customs Tariff is to be governed by the Generpal Rules for the Interpretation of the Harmonized System and the Canadian Rules and the Explanatory Notes to the Harmonized Commodity Description and Coding System. ... Deputy Minister of National Revenue (Customs & Excise) [7] ', a classification matter before the Tribunal dealing with television converters, the Tribunal, in concluding that television converters were parts to television receivers, wrote: Although the television can operate without a converter by increasing the number of channels a television is capable of receiving, a converter contributes directly to the main function of a television receiver, that being the reception of audio-visual signals. ...

H a Fawcett & Son, Limited v. Her Majesty the Queen, [1979] CTC 303, 79 DTC 5224 Dubé, J:—The main issue to be determined in this case is whether the plaintiff corporation in its fiscal year ending November 30, 1975 was associated with Fawcett Enterprises Limited and Son Valley Ranch Limited under paragraph 256(1)(b) of the Income Tax Act on the basis that all three corporations are controlled by the same person, George C Fawcett. ... If it had been the intention of Parliament to exclude from the provisions of paragraph 256(1)(b) shares which were acquired by an executor or a trustee by virtue of the death of any other person it would have done so in clear unambiguous terms, as it did for the purposes of other subsections.* [5] The appeal therefore should be dismissed with costs. 1 Judson, J in MNR v Consolidated Holding Co, [1974] S.C.R. 419 at 423; [1972] CTC 18 at 20; 72 DTC 6007 at 6008. 2 T Thurlow, J (now ACJ) in Career Girl Store v MNR, [1967] 1 Ex CR 21; [1966] CTC 330; 66 DTC 5244. 3 + Vineland Quarries & Crushed Stone v MNR, [1966] Ex CR 417, 429; [1966] CTC 69; 66 DTC 5092. The reasons and conclusions of Cattanach, J were adopted by the SCC—see 67 DTC 5283 at 5284. 4 § Buckerfield’s Limited v MNR, [1965] 1 Ex CR 299, at 305; [1964] CTC 504 at 509; 64 DTC 5301 at 5304. 5 See subparagraph 256(7)(a)(ii) added by SC 1977-78 c 1, section 99, which reads (7) Where control deemed not to have been acquired. ...

The Shorter Oxford English Dictionary gives the following meanings for the word ‘ agency ’ ’: “1. ... Established or stable conditions —1777; organization, footing — 1799. 3. ... That which is established; a settled constitution or government — 1793. 2. ...

Having done so, it did seem logical to the appellant that Ogilvie paid $185,000 for only a piece of paper — the lease — giving that company the rights inherent therein. ... It was as much “notional” to Ogilvie as it was to Dominion — it simply did not exist. ... As I see it, that was a purely mathematical exercise — a procedure specifically rejected as applicable by Mr Wise. ...

A set of 9000 series comes as follows: a) I on = 9000 sheets b) 2 on = 4500 sheets c) 3 on = 3000 sheets d) 6 on = 1500 sheets The 6000 series means 6000 individual cards or faces. The 6000 series comes as follows: a) 7 on = 6000 sheets b) 2 on = 3000 sheets c) 3 on = 2000 sheets d) 6 on = 1000 sheets All bingo supplies were ordered from C.I.C.. ... The Crown based upon the assumptions as outline in paragraphs 58 and 59 above if correct would have unreported income against Spryfield Bingo in the following amounts: UNREPORTED INCOME TAX EVADED 1984 $ 345,321.00 $ 89,602.52 1985 $ 464,458.00 $167,428.24 1986 $ 513,809.00 $190,555.07 1987 $ 359,935.00 $135,117.21 $1,683,523.00 $582,703.04 61. ...

At this time Oriole engaged the services of D & S Petroleum Consultants Ltd of Calgary to prepare a valuation of Oriole’s assets. ... There was also a deficiency problem in respect of the Blackfoot property which reduced the value of the assets by $400,000; as a result all the items in the transaction — the shares, employment contract and money payments — were renegotiated and all, including the employment contract, were reduced on a pro rata basis. ... Mr Penner, a chartered accountant practising as a partner with Thorne & Riddell in Calgary, was also called as a witness by the appellant. ...

A-Supreme Nursing & Home Care Services Inc. v. The King, 2023 TCC 39 Docket: 2017-689(GST)G BETWEEN: A-SUPREME NURSING & HOME CARE SERVICES INC., Appellant, and HIS MAJESTY THE KING, Respondent.   ... FACTS [1] A-Supreme Nursing & Home Care Services Inc. (the Appellant) places nurses in long-term care facilities and nursing homes (the “Clients”). ... (the “Act ”). B. Background: [4] The Appellant is incorporated under the Business Corporations Act of Ontario, with its head office located in Toronto, Ontario. ...