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If there is a contract of employment, by definition, remuneration thereunder is income for purposes of Part I of the Income Tax Act.t [4] 1 “It is not necessary, on this appeal, to consider whether amounts paid as “strike pay’’ may, as such, be income receipts for income tax purposes. 2 ** Compare Snook v London & West Riding Investments Ltd, [1967] I All ER 518 and Minister of National Revenue v J A Cameron, [1974] S.C.R. 1062; [1972] CTC 380; 72 DTC 6325. 3 + Compare Griffiths (Inspector of Taxes) v J P Harrison (Watford), Ltd, [1962] 1 All ER 909; Bishop (Inspector of Taxes) v Finsbury Securities, Ltd, [1966] 3 All ER 105, and FA ET AB Ltd v Lupton (Inspector of Taxes), [1971] 3 All ER 948. 4:] See section 3 of the Income Tax Act. ...

HECKMAN J.A.   BETWEEN: MIDJOHODO FRANCK GLOGLO Appellant and MINISTER OF NATIONAL REVENUE Respondent Heard at Montréal, Quebec, on January 16, 2024. ... REASONS FOR JUDGMENT OF THE COURT BY: HECKMAN J.A.   Date: 20240116 Docket: A-225-22 Citation: 2024 FCA 13 CORAM: BOIVIN J.A. ... FEDERAL COURT OF APPEAL NAMES OF COUNSEL AND SOLICITORS OF RECORD DOCKET: A-225-22   STYLE OF CAUSE: MIDJOHODO FRANCK GLOGLO v. ...

That group and their respective interests in the land were as follows:— Mohawk Horning Limited — 20 per cent Maple Park Development Limited — 20 per cent Dekston Limited — 10 per cent Dennis O’Leary — 10 per cent Vincent De Benedictis — 10 per cent Anthony Di Silvestro — 10 per cent George L. Schneider — 10 per cent George L. Schneider Limited — 10 per cent Of those, in addition to the appellant herein, Maple Park Development Limited, Dekston Limited, George L. ... Graham & Sons Ltd., [1956] 3 All E.R. 624 at 630; Clarkson Co. Ltd. v. ...

LEBLANC J.A.   Date: 20210721 Docket: A-223-19 Citation: 2021 FCA 145 CORAM: WEBB J.A. ... These exclusive purposes are: ● to regulate a sport and the way it is played; ● to promote the sport; ● to oversee a structure of local clubs, and regional and provincial bodies involved in the sport; ● to operate a training program that brings promising athletes from the grass-roots level to national and international levels through various qualifying competitive events; ● to operate a national team to participate at international competitions; ● to stage and sanction local, regional, provincial and national competitions; ● to act as a Canadian representative of an international federation controlling the sport; ● to provide a training and certification program for coaches and referees; and ● to carry out fund-raising activities and re-distribution of funds for local, regional and provincial member organizations. [23] In addition to these listed purposes and functions, the First Letter included the following: Alternatively, the following types of organizations may also qualify as a RCAAA: ● organizations established to hold international or national multi-sport games in Canada; ● organizations established to hold international single-sport events in Canada; ● organizations that maintain and operate facilities for the training of elite athletes that are an extension of international multi-sport games; or ● organizations that provide multi-sport training centres for high-performance athletes that have been identified by their national sports organizations. ... Drouin Deputy Attorney General of Canada For The Respondent   ...

Marlin testified, and the defendant's counsel acknowledged, that the reason for the plaintiff’s acquisition of the Speedway land was to obtain qualified assets within the meaning of the Investment Contracts Act of Alberta)", (A.B. p. 36; C.T.C. 108), the learned Trial Judge found, nevertheless, that when the appellants "... contrived to structure this particular and chosen transaction... they... must be held to have intended: — to hold the land for only seven years or less; — not to develop it or to operate the speedway business; — not to earn revenue from it over and above the costs of carrying it; — to sell it for profit at the most propitious moment within the seven- year period after acquisition? ... The subject-matter of the realization — In this connection the authors comment: “... property which does not yield to its owner an income or personal enjoyment merely by virtue of its ownership is more likely to have been acquired with the object of a deal than property that does.” ... " He went on to add “... I very much doubt that, for many years at least... ...

The Statutory Scheme The relevant sections of the Income Tax Act for the purposes of this appeal are: 149.(1) No tax is payable under this Part upon the taxable income of a person for a period when that person was (f) "registered charity" — a registered charity; 248.(1) Definitions — In this Act, "business" — "business" includes a profession, calling, trade, manufacture or undertaking of any kind whatever and, except for the purposes of paragraph 18(2)(c), an adventure or concern in the nature of trade but does not include an office or employment; "registered charity" — "registered charity" has the meaning assigned by subsection 110(8); 110.(8) Definitions — In this section, (c) "registered charity" — “registered charity" at any time means (i) a charitable organization, private foundation or public foundation, within the meanings assigned by subsection 149.1(1), that is resident in Canada and was either created or established in Canada, or (ii) a branch, section, parish, congregation or other division of an organization or foundation described in subparagraph (i), that is resident in Canada and was either created or established in Canada and that receives donations on its own behlaf, that has applied to the Minister in prescribed form for registration and that is at that time registered as a charitable organization, private foundation or public foundation. 149.1(1) Definitions — In this section, section 172 and Part V, (a) "charitable foundation" — "charitable foundation" means a corporation or trust constituted and operated exclusively for charitable purposes, no part of the income of which is payable to, or is otherwise available for, the personal benefit of any proprietor, member, shareholder, trustee or settlor thereof and that is not a charitable organization; [Emphasis added] (b) "charitable organization" — “charitable organization” means an organization, whether or not incorporated, (i) all the resources of which are devoted to charitable activities carried on by the organization itself, (ii) no part of the income of which is payable to, or is otherwise available for, the personal benefit of any proprietor, member, shareholder, trustee or settlor thereof, (iii) more than 50% of the directors, trustees, officers or like officials of which deal with each other and with each of the other directors, trustees, officers or officials at arm's length, and (iv) where it has been designated as a private foundation or public foundation pursuant to subsection 110(8.1) or (8.2) or has applied for registration under paragraph 110(8)(c) after February 15, 1984, not more than 50% of the capital of which has been contributed or otherwise paid in to the organization by one person or members of a group of persons who do not deal with each other at arm's length and, for the purpose of this subparagraph, a reference to any person or to members of a group does not include a reference to Her Majesty in right of Canada or a province, a municipality, another registered charity that is not a private foundation, or any club, society or association described in paragraph 149(l)(1); (f) "private foundation" — “private foundation" means a charitable foundation that is not a public foundation; (g) "public foundation" — “public foundation” means a charitable foundation which, (i) where the foundation has been registered after February 15, 1984 or designated as a private foundation or charitable organization pursuant to subsection 110(8.1) or (8.2), (A) more than 50% of the directors, trustees, officers or like officials deal with each other and with each of the other directors, trustees, officers or officials at arm's length, and (B) not more than 50% of the capital contributed or otherwise paid into the foundation has been so contributed or otherwise paid in by one person or members of a group of such persons who do not deal with each other at arm's length, or (ii) in any other case, (A) more than 50% of the directors or trustees deal with each other and with each of the other directors or trustees at arm's length, and (B) not more than 75% of the capital contributed or otherwise paid in by one person or by a group of persons who do not deal with each other at arms' length and, for the purpose of clause (i)(B), a reference to any person or to members of a group does not include a reference to Her Majesty in right of Canada or a province, a municipality, another registered charity that is not a private foundation, or any club, society or association described in paragraph 149(l)(1); [Emphasis added.] ... Issue A — Is the Appellant Operating Exclusively for Charitable Purposes At the outset, and in response to a question from the Court, counsel for the respondent agreed that the imposition of the appellant, a corporate entity, into the Association's fund raising activities is not a factor in the determination of the issues in this appeal. ... When can a business be said to be related to the objects of a charity: — When, in my view, there exists between the commercial activity in question, considered in itself, and the charitable objects of the charity such a relationship that it can be said that by engaging in the commercial activity in question the charity is, in effect, contributing to the realization of its charitable objects. ...

WEBB J.A.   BETWEEN: ELIAS LEVY Appellant and HER MAJESTY THE QUEEN Respondent Heard by online video conference hosted by the registry on May 12, 2021. ... Nadon” J.A.   FEDERAL COURT OF APPEAL NAMES OF COUNSEL AND SOLICITORS OF RECORD DOCKETS: A-349-19, A-350-19, A-351-19 AND A-95-20   STYLE OF CAUSE: ELIAS LEVY v. ... Drouin Deputy Attorney General of Canada For The Respondent   ...

The brochure submitted in the applicant's brief describes the goods in issue as ”... free standing Compactor, Container and Base Frame... ... But at the warehouse level there is a lot of waste, of course, which has occurred to this produce enroute — from California — MEMBER DEACHMAN: That is they are culling leaves off it and that sort of thing — stems and the like? THE WITNESS: Yes, that's right, and even thrown complete boxes, say, of peaches or whatever they happen — oranges, if they are considered as being up to quality, but they must be removed immediately from that place. ...

He observed that, under the scheme, distributions of capital – unlike distributions of income – are not taxed in the hands of the unitholder until they exceed the amount invested. ... Van Steenis’s appeal. [7]   Mr. Van Steenis now appeals to this Court. ... Drouin Deputy Attorney General of Canada For The Respondent   ...

REASONS FOR ORDER BY: WEBB J.A.   Date: 20180328 Docket: A-176-17 Citation: 2018 FCA 66 Present:   WEBB J.A. ... Webb" J.A.   FEDERAL COURT OF APPEAL NAMES OF COUNSEL AND SOLICITORS OF RECORD DOCKET: A-176-17   STYLE OF CAUSE: HUMANE SOCIETY OF CANADA FOUNDATION v. ... Drouin Deputy Attorney General of Canada For The Respondent   ...