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These minimal contributions enabled the curatorship to avoid paying administration fees. 9 On October 21, 1986, the curator was informed by the Service de la surveillance de l'administration des curateurs et tuteurs of the office of the Public Curator of Québec that [TRANSLATION] “a registered retirement savings plan is not a permissible investment consistent with those set out in arts. 981o et seq. of the Civil Code ”. ...

& D. Development Corp. and or suing same. Larry will not be an employee of the company, but will have a say in the day-to-day operations of the company. ...

However, with regard to determining the terms of the contract he said at 2057: I believe that where it is expressly or impliedly alleged in cases of the kind under appeal that a taxpayer having a relationship to a company similar to that which existed between the appellant and Coulter Copper & Brass Ltd. was acting as its agent in negotiating a verbal contract of employment with him, convincing confirmatory proof of some kind should be forthcoming to establish the terms of the contract relied on in making deductions in the computation of income. ...

If I set aside Route A which was an indirect acquisition of Omnibus shares by the Collyer Family Company (324) and not involved in this appeal, the Appellant's cost of his direct and indirect ownership of Omnibus shares and warrants may be summarized as follows: Omnibus Shares and Warrants Cost to Appellant Route B 4.4% of 0089 which held 8.06% of the Omnibus shares on May 11, 1987 $ 610 10,687 Route C 4.17% of 606 which then held 10% of the Omnibus shares 25,000 Route D 25,000 Omnibus shares plus 25,000 Omnibus warrants 100,000 Route E 3,333 Omnibus shares 15,000 Route F 24,870 Omnibus shares plus 9,257 warrants upon winding-up of 606 (25,000) 96,373 Totals 53,203 Omnibus shares plus 34,527 Omnibus warrants plus 4.4% of 0089 $222,670 It is the amount of $222,670 which the Appellant seeks to deduct in 1987 as a business loss. ...

.: — Ferme Klosterhos Inc. (Klosterhos) is contesting income tax assessments made by the Minister of National Revenue (the Minister) for the 1988, 1989, 1990 and 1991 taxation years. ...

If so determined, the second issue is whether the reassessment for the 1989 year is statute-barred or does the assessment fall within the provisions of subparagraph 152(4)(«)(i) of the Income Tax Act (the “Acf ’). ...

More precisely, having regard to the submissions of the parties, did each transaction give rise to an exempt supply as regards the Appellants. [57] Certain general provisions of the Goods and Services Tax portion of the Excise Tax Act should be kept in mind. [58] Section 165 enacts that every recipient of a taxable supply made in Canada shall pay to the Government of Canada tax in respect of the supply equal to 7 % of the value of the consideration for the supply, unless it is a zero-rated supply. [59] The definitions of certain terms and expressions of general import used in section 165 or elsewhere in the Excise Tax Act should be noted. ... "Alban Garon" J.T.C.C. [1]               Page 23b of the transcript, line 24 to page 24, line 12. [2]               Section 7 quoted above and referred to at the hearing of these appeals was amended by section 88, c. 10 of the Statutes of Canada, 1997 and was made retroactive to September 14, 1992 for certain purposes. ...

The usual rule — and I see no reason why it should not apply in income tax appeals — is set out in Odgers’ Principles of Pleading and Practice, 2nd edition at page 532: The “burden of proof” is the duty which lies on a party to establish his case. ...

He was a shareholder in a limited company known as Island Muffler Sales Service & Manufacturing Limited and together with one Richard C. ... One hundred thousand dollars came from Cedar Hill Cross Roads Estates, which was one of the partnership businesses; $15,000 came from Island Muffler Sales Service & Manufacturing Limited and a further $15,000 from Cedar Hill Cross Roads Estates. ... He referred to the case of British Insulated & Helsby Cables Ltd. v. ...

Coopers & Lybrand (Amsterdam) were appointed auditors. Unsworth explained that managing directors were analogous to officers of a Canadian corporation while supervisory directors were likened to the "Canadian-style director". ... He said at page 198 (D.T.C. 5122): “What is income from "a business other than an active business” must mean income from a business that is in an “absolute state of suspension”. ” And at page 199 (D.T.C. 5123): “Any quantum of business activity that gives rise to income in a taxation year for a private corporation in Canada is sufficient to make mandatory the characterization of such income as income from an 'active business carried on in Canada'. ... In L & F Holdings Ltd. v. M.N.R., [1975] C.T.C. 2192; 75 D.T.C. 150 (T.R.B.), Roland St-Onge, Q.C. ...