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It is, of course, obvious that legislatures may — and to govern effectively—must treat different individuals and groups in different ways. ... There are only a limited number of mechanisms by which a shareholder may legitimately put himself personally in control of funds of a corporation — salary, dividends, and interest primarily. ...

Lagueux & Frères Inc., [1974] C.T.C. 687, 74 D.T.C. 6569 (F.C.T.D.); The Queen v. ... In Lagueux & Frères the contract in issue gave the "lessee" an option to purchase the equipment at a nominal price at the end of the lease. ...

.: — These appeals were heard together on common evidence. The years under appeal for Mike Adams are 1984, 1985, 1986, 1987 and 1988. ... Rayner & Keeler Ltd. (No.2), [1967] 1 A.C. 853 at page 935; Angle v. ...

Rutland Moving & Storage Ltd., [1991] l C.T.C. 517 at 521 (B.C.C.A.) ... In an article entitled, “The Taxation of Corporate Reorganizations”, which appeared in Volume 4 of the 1997 edition of the Canadian Tax Journal (Tab 13), author Mark Brender of the law firm of Goodman, Phillips & Vineberg in Montreal, Quebec, specifically addressed the meaning of the word “any” as it appears in subsection 55(2) of the Act as follows at page 807 of the article:...there is no statutory basis for limiting the consolidation of safe income to controlled or significantly controlled corporations and that the safe income of any corporation should be included in the computation of safe income of the parent, regardless of how small the interest of the parent may be. 26. ...

In support counsel primarily relied on Ben Matthews & Associates Ltd. v. ... M.N.R., [1978] C.T.C. 2082, 78 D.T.C. 1087 (T.R.B.); Atkins & Durbrow Ltd. v. ...

.: — The Minister of National Revenue reassessed the Appellant by Notices of Reassessment dated June 14, 1993 for its 1989, 1990 and 1991 taxation years disallowing dividend refunds to it as follows: 1989- $109,254 1990- $126,386 1991- $113,570 TOTAL- $349,210 The Appellant claimed the dividend refund in respect of the following dividends paid on its Class “B” shares to Tingley Leasing Venture Capital Inc. ... Maritime Telephraph & Telephone Co. v. Canada) [1992] 1 C.T.C. 264, 92 D.T.C. 6191 (F.C.A.), MacGuigan, J.A. at page 267 (D.T.C. 6194), without reasons for the reference, said, This interpretation is, I believe, supported by the only extrinsic evidence available. ...

I conclude without difficulty that “ Delhi Farms" needed money to survive and that the "company" loaned the money to "Delhi Farms" and that obviously some of the money was used for purchasing equipment, supplies and paying off the mortgage to the Bank of Montreal. ... Kanters did say that they now intend to make arrangements to pay it back since it appears that ” Delhi Farms" is now viable. ...

The decisions in Berman & Co. v. Minister of National Revenue, 61 D.T.C. 1150 (Can. ... Counsel for the appellant argued that the expenses in issue, unlike the transfers of funds, were not treated as loans or advances of funds by the appellant to ITB in their respective financial statements and that the Supreme Court of Canada’s decision in Stewart & Morrison Ltd. v. ...

Currently, the contribution is equal to the required maximum of ½ of 1% of basic payroll. 6. ... But the Long Term Disability Plan (which is exclusively funded by the employees – 19.11.4) is an insurance plan with The Mutual Life Assurance Company of Canada. ...

He also admitted that the tables were the determining factor in his recommendations. [25] The work performed by the appellants was excepted from insurable employment under paragraph 3(2)(c) of the Unemployment Insurance Act (“the Act ”). ... Bayside Drive-In Ltd., A-627-96; Ferme Émile Richard & Fils Inc. v. ...