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.: 1 The Appellant in these income tax appeals seeks the determination of a question of law under paragraph 58(1)(a) of the Tax Court of Canada Rules (General Procedure). 2 The question to be determined is whether or not the Tax Court of Canada has the jurisdiction to consider, give effect to, and apply the Indian Income Tax Remission Order (the “ Remission Order ”). ...

The year under review is 1994. 2 The issues are whether the appellant is liable for interest under subsection 161(2) and to a penalty under section 163.1 of the Income Tax Act (“the Act ”). 3 There is no disagreement of any substance about the facts. ...

The details of the rental losses are set forth in Schedules A1, A2 and A3 to the Minister's Reply as follows: Schedule “A1” 1992 Gross rental income $16,750 EXPENSES: Maintenance and Repairs $ 669 Interest 18,556 Property Taxes 6,963 Insurance 268 Utilities 1,379 Telephone 451 Travel 310 Less: Personal use (2,391) 26,205 Net Income (Loss) ($9,455) Schedule “A2” 1993 Gross rental income $8,160 EXPENSES: Maintenance and Repairs $1,648 Interest 8,225 Agency fees 1,705 Professional fees 102 Light, Heat water 2,016 Insurance 316 Property Taxes 1,893 15,905 Net Income (Loss) ($7,745) Schedule “A3” 1994 Gross rental income $6,362 EXPENSES: Maintenance and Repairs $2,378 Interest 7,553 Light, Heat water 2,017 Insurance 414 Property Taxes 2,049 14,411 Net Income (Loss) ($8,049) It is to be noted that Schedule A1 actually reflects income and expenses related to the Property as well as to another property which the Appellant rented out in that year. ...

Schneider of Deloitte & Touche respecting this matter. A Notice of Assessment mailed on April 27, 1995 to the Appellant showing a total amount assessed of $29,685.79 had the following notation: The liability under subsection 160(1) of the Income Tax Act and section 19 of the Income Tax Act- Saskatchewan, in the amount of $29,685.79, in respect of a transfer on or about June 16, 1989 from High-line Drilling (International) Inc. to Mary Christensen of the property located at 151 Wathaman Terrace, Saskatoon, Saskatchewan. ... Mervin Schneider (“Schneider”), Chartered Accountant and partner of Deloitte & Touche, was in charge of the audit and income tax preparation of High-line, Holdings and Albert. ...

Paragraph (c) of subsection 4 of section 2 of By-Law # 10 reads at page 37: (c) Provision shall be made for specialized ministries such as music, Christian education, and visitation. ... Quite apart from the appellant’s own testimony concerning the role of music in the Pentecostal church, as well as the numerous Biblical references in both the Old and the New Testaments, the Dictionary of Pentecostal and Charismatic Movements (Burgess & McGee) devotes seven pages to Pentecostal and Charismatic Music. ...

Kramer, Hillside Shopping Centre Ltd. and McCallum Hill & Co. Ltd. v. ... The arbitrator held on the evidence that this by-law was an independent zoning enactment, part of an overall city plan and not part of the expropriation proceedings — although passed of course with knowledge of the Wascana Centre Scheme. ...

He said in his evidence that he had an informal discussion with a tax lawyer at the Vancouver firm of Russell & Dumoulin about this proposed method of financing the purchase, and was advised that, in order to avoid the pitfalls of subsection 15(2) of the Act, bona fide arrangements must be made for repayment within a reasonable time. ... Commissioner of Taxation of the Common wealth of A ustralia: [3] Their Lordships are of opinion that the word “arrangement” is apt to describe something less than a binding contract or agreement, something in the nature of an understanding between two or more persons — a plan arranged between them which may not be enforceable at law. ...

Under the terms of this debenture, if it was converted on or before December 31, 1986, Omnibus was obligated to issue the “ qualifying shares" and in compliance with subsection 192(4) of the Act designate an amount in respect of those shares not exceeding 25 per cent of the consideration upon which they were issued to a maximum of $80,000 as the SPTC. ... The letter also noted that no remittance of the penalty “appears to have been made" with the designation forwarded on October 17 and “ consequently, the designation in question cannot be considered to be filed as a valid designation in accordance with subsection 194(7) as the applicable penalty of $8,000 has not been remitted”. ...

Without a reasonable expectation of profit no business exists. [...] Once it is conceded, either by the very fact of applying section 31 or otherwise, that a business exists, the taxpayer's reasonable expectation of profit ceases to be a factor in determining whether he is to be subject to the restrictions of section 31. ... Leblanc was not ”... merely testing the water. He had plunged fully and without reservation into the water.” ...

He maintained that, having regard to the existing case law, with the exception of the decision of this Court in Fortin & Moreau v. ... In any event, interpretation bulletins are used by the courts where the Act is ambiguous (/. ...