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Neither the offer nor the pre-contract was filed at the hearing. [9] The same agreement (Exhibit A-1), at page 9 in the clause titled [TRANSLATION] "Notations required under s. 9 of the Act to authorize municipalities to collect duties on transfers of immoveables ", states the following regarding the consideration and the amount making up the tax base of the transfer duties: [TRANSLATION] 3. ...

The Department, in Interpretation Bulletin IT-322R (¶ 5675), and the Supreme Court of Canada in Moldowan v. ...

(“the payer”) during the period from June 5 to August 12, 1995, did not meet the requirements for being considered as having been performed under a contract of service within the meaning of the Unemployment Insurance Act (“the Act ”). [2] The appellant testified at length. ...

Reasons for judgment Lamarre Proulx, J.T.C.C. [1] The appellant is appealing from the assessment made by the Minister of National Revenue (“the Minister”) under the Excise Tax Act (“the Act ”) for the period from November 1, 1991, to July 31, 1995. [2] The facts on which the Minister relied are set out as follows in paragraph 2 of the Reply to the Notice of Appeal (“the Reply”): [TRANSLATION] (a) the appellant is a supplier registered for the purposes of the Excise Tax Act, R.S.C. 1985, c. ...

This amount was not to be payable, however, until the earlier of two dates – the date upon which 85% of the lots developed on the land were sold, and the date upon which the Appellant had a cash flow sufficient to make the payment. ...

Under subsection 15(1) of the Income Tax Act, the Appellant received shareholder benefits in the following respective amounts: 1996- $1,126.28 1997- 2,072.31 1998- 1,892.06 In the above table, I have simply used the average cost of each course as being the value of the benefit within the meaning of subsection 15(1). [12] In paragraph 12 of the Respondent's Reply to the Notice of Appeal, the Minister of National Revenue conceded that the Appellant is entitled to a tuition credit in the amount of $272.50 for the 1995 taxation year with respect to the fee he paid for the labour market training project – "Right Choice Driver Training" being a course which he took in 1995. ...

He thus referred to the letter dated May 28, 1998 which reads as follows: [TRANSLATION] St-Onge & Roy, Solicitors Pierre St-Onge 440 avenue Brochu, Suite 201 Sept-Îles, Quebec Subject: Employment Insurance Act Pierre Chevarie S.I.N.: 216-318-121 Dear Sir, We have read your letter of May 18, 1998 concerning your client Pierre Chevarie's application to appeal. ...

Reasons for judgment Tardif, J.T.C.C. [1] This is an appeal from a Goods and Services Tax (“GST”) assessment dated May 9, 1997, that was made under the Excise Tax Act (“the Act ”) for the period from January 1, 1993, to December 31, 1995. [2] Jean Labranche, the directing mind of the appellant company, began by tracing the history of his career. ...

Reasons for judgment Charron, D.J.T.C.C. [1] This appeal was heard at Québec, Quebec, on February 19, 1999, to determine whether the appellant held insurable employment within the meaning of the Unemployment Insurance Act (“the Act ”) from June 17 to September 20, 1996, and from May 5 to July 18, 1997, when she worked for 9018-7683 Québec inc., which carried on business under the firm name Passion-Krafts International (the payer). [2] By letter dated January 13, 1998, the respondent informed the appellant that the employment was not insurable because it did not meet the requirements for a contract of service and there was no employer-employee relationship between the payer and her during the periods at issue. ...

Hamlyn" J.T.C.C. [1]               McClurg v. Canada, [1990] 3 S.C.R. 1020, 91 DTC 5001 (S.C.C.), at page 5011. ...