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The February 1994 Department of Finance Technical Note that accompanied the amending legislation states in part: New clause 37(8)(a)(ii)(B) contains the new alternative method for determining SR&ED expenditures. [...] If the taxpayer does elect the alternative method, the following expenditures will be considered to be for SR&ED carried on in Canada and therefore included in the taxpayer’s SR&ED pool under subsection 37(1): (1) an expenditure of a current nature (generally a lease expense) that was for and all or substantially all attributable to the use of premises, facilities or equipment for the prosecution of SR&ED in Canada, unless the expenditure was for general purpose office equipment or furniture. [...] ...

Hughes & Co. Holdings Ltd., (1994), 94 D.T.C. 6511 (Fed. T.D.), is the only case that deals with the term “part- time employee”. ... This interpretation is in accordance with the definition found in the Dictionary of Canadian Law, Dukelow & Nuse, Carswell, referred to in R. v. ...

Rip” J.T.C.C. [1]           Toby Perry appealed his income tax assessments for 1989 and 1990 on the same basis as Stanley Kelley, Clare Smith and Dale Smith. ... His appeals are therefore dismissed with costs. [2]           In his submission, respondent’s counsel asked that no weight be given to Mr. ...

In the draft contract – Exhibit R-1- Blaney had intended to limit Butterfield to providing services exclusively to SDC during the term of the contract but that provision did not make it into the signed contract- Exhibit A-1. ... Pursuant to the paragraph 9(3) of the Tax Court of Canada Rules (E.I.) an intervener: "... may state in the notice of intervention that the intervener intends to rely on the reasons set out in the notice of appeal received by the intervener or the reasons set out in the notice of intervention of another intervener. ...

Subsection 280(1) of the Excise Tax Act (“the Act ”) provides: “280. (1) Subject to this section and section 281, where a person fails to remit or pay an amount to the Receiver General when required under this Part, the person shall pay on the amount not remitted or paid (a) a penalty of 6% per year, and (b) interest at the prescribed rate, computed for the period beginning on the first day following the day on or before which the amount was required to be remitted or paid and ending on the day the amount is remitted or paid.” [5] The onus is on the appellant to show that the reassessment is in error. ... It is sufficient for present purposes to reproduce these portions of B-074: “ Introduction This bulletin explains the guidelines for the reduction of penalty and interest in ‘wash transaction’ situations. ...

Paterson & Associates Ltd. ("Associates") who owned 50 per cent and Richard Gillard who owned 25 per cent. ... Paterson & Associates Ltd. ("Associates"). Paterson first participated in real estate ventures with Giuliani and Gillard in 1979 when they purchased an apartment building of approximately 100 units in Ottawa. ...

The second farm, “ Rockhurst” comprised 166 acres and was acquired in the name of a company called Rockhurst Farms Ltd., the shares of which were owned by the appellant's wife and his children. ... But he is a self-described workaholic and there is no doubt that his “ major preoccupation”, the term used in Moldowan, was farming. ...

Tarantino tax returns of the appellant for the 1978-81 years and he agreed the business of Universal was described as "Mortgage Broker and Real Estate” or “ Broker, Sales, Real Estate" or "Management Consultant and Real Estate Broker”. ... Evidence of transactions of the sale and purchase of real estate by an appellant after the years under review in an appeal is admissible: Osler Hammond & Nanton Ltd. v. ...

& Mrs. Higgins instructed a certified general accountant to travel as soon as possible to Sparwood to conduct an audit. ... To extrapolate, I find the following as fact: — By February 20, 1987 the appellant was generally aware of operational shortages and the probability of non-remittances tax withholdings; —Shortly thereafter he received the request to act as director; —On February 22 he and the Higginses authorized an accounting review which commenced March 23; —He signed the consent dated February 4 around March 23; —He received the accountant's information concerning the remittance failures on March 31 and then told the accountant to go back for another check to determine where the money may have gone; —By April 15 the accountant had corresponded with Revenue Canada concerning the non-remittances; and —The appellant resigned April 16 and attended an April 29 meeting in the capacity of an investor. ...

Firstly, if the estate would trade their property for the apartment building / would purchase the apartment building outright from the estate for $165,000. net. ... Appeal dismissed. 1 *For an earlier and similar assessment see S & S Properties Ltd v The Queen, [1978] CTC 412; 78 DTC 6294, per Walsh, J. at 419 (DTC 6299). 2 *In Hiwako Investments Ltd v The Queen, [1978] CTC 378; 78 DTC 6281, Jackett, CJ said by way of obiter dicta at 384 (DTC 6285): “I might also add a word with reference to "secondary intention’. ...