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L & K Farms Ltd. v. The Queen, docket 98-570-IT-G Date: 19990903 Docket: 98-570-IT-G BETWEEN: L & K FARMS LTD., Appellant, and HER MAJESTY THE QUEEN, Respondent. ... L & K ordered a special tractor powered by a Cummins Diesel engine, which was L & K's choice. ... Even if serial number D-100035 was not inserted into L & K's copy of Form A on December 29, 1993, the goods then passed to L & K. ...

Wise in determining indicated after-tax earnings of $99,000: 1977 1976 Adjusted pre-tax earnings $ 70,520 $218,010 Weighting factors 2 1 Average indicated pre-tax earnings, rounded off 120,000 Income tax: Indicated earnings $120,000 Less: 3% allowance for inventory ($673,751) (20.213) $ 99,787 LESS: Income tax at 21% on $99,787 (20,955) Indicated after-tax earnings, rounded off $ 99,000 [Translation.] ... His calculation of the indicated aftertax net earnings is as follows: Average adjusted pre-tax net earnings: 1976 * 254,420.00 1977 111,022.00 Total $365,442.00 divided by 2 Indicated pre-tax earnings * 182,721.00 Less: Income tax: Indicated earnings * 182,721.00 Less: 3% allowance for inventory 0000,000) (19,500.00) * 163,221.00 Less: income tax of 21% on $163,221 * (34,277.00) Indicated after-tax net earnings, * 148,444.00 rounded off * 146,400.00 [Translation.] ... Muller & Co.’s Margarine Ltd., [1901] A.C. 217, another House of Lords decision, Lord Macnaghten said at page 223: What is goodwill? ...

(“Skylight”), Suresh Kumar Aravindakshan (“Suresh”) and Titus George (“Titus”) in respect of assessments issued to them, under the Employment Insurance Act (the “ EIA ”) [1] and the Canada Pension Plan (the “ CPP ”) [2], by the Minister of National Revenue (the “Minister”), as represented by the Canada Revenue Agency (the “CRA”). ... ELLEITHY: … I did notice that … a lot of the wording is very similar. ... Aravindakshan is earning 70 % agent’s commissions as agreed at the time of acceptance. ...

Hadiken Concrete & Supply Ltd. v. The Queen, docket 96-3382-IT-G Date: 19960612 Docket: 96-3382-IT-G; 96-3383-IT-G BETWEEN: HADIKEN CONCRETE & SUPPLY LTD., LAWRENCE HADIKEN Appellants, and HER MAJESTY THE QUEEN, Respondent, Reasons for Judgment Bell, J.T.C.C. ... FACTS [2] At the commencement of his submissions, Respondent's counsel said that if the sale by Lawrence Hadiken ("Lawrence") was on capital account, then the sale by Hadiken Concrete & Supply Ltd. ... This was a "roll-over" pursuant to section 85 of the Income Tax Act (" Act "). ...

Muir Cap & Regalia Limited v. Minister of National Revenue, 91 DTC 533, [1991] 1 CTC 2342 (TCC) Mogan, T.C.J. ... (the ” numbered company") and all of the former shareholders of the appellant took shares in the numbered company in the same proportion as their former shareholdings in the appellant. ... The ratio of current assets (including term deposits) to current liabilities in 1983 and 1984 is even more significant: 1983 1984 Term Deposits $245,977 $254,288 Payable to Parent Company $229,800 $169,698 Retained Earnings $119,218 $206,594 1983 1984 Current Assets $400,779 $448,728 Current Liabilities $ 38,699 $ 59,228 On the above facts, I cannot conclude that the appellants fund of term deposits, was“ employed and risked in the business” in the words of Le Dain, J. which were adopted by the Supreme Court of Canada in Ensite. ...

Atlantic Mini & Modular Homes (Truro) v. The Queen, docket 98-1693-GST-I (Informal Procedure) Date: 19990719 Docket: 98-1693-GST-I BETWEEN: ATLANTIC MINI & MODULAR HOMES (TRURO) LTD., Appellant, and HER MAJESTY THE QUEEN, Respondent. ... The Minister is of the opinion that the used mobile homes sold by the Appellant are residential complex within the meaning of the Excise Tax Act (the " Act ") and it follows that GST should be remitted on the taxable supplies provided by the Appellant. ... " [16] A "residential complex" includes a mobile home as defined under subsection 123(1) of the Act which says: "... ...

Ronda Holdings Limited, Checker Industrial Rubber & Tire Limited, Cartier Parking Limited v. ... Law — Cases at Law — Analysis 4.01 Law The main provisions of the Income Tax Act involved in this case are 251(2)(a), 251(5)(a), 256(l)(a) to (e) and 256(2). ... W Ralston & Co (Canada) Ltd v MNR, [1982] CTC 2108; 82 DTC 1128; 9. ...

Now to do this, once again, we are talking of 1,200 to 1,400 employees, so for us — the practical aspect — the approach — the easiest and most practical possible — was to use the already existing systems, the Admiral company’s payroll system; and by using this system former Admiral employees were able to tell us — to give us information on amounts owed to each employee for services rendered up to November 4. ... Act — case law — analysis 4.01 Act The main provisions of the Income Tax Act, R.S.C. 1952, c. 148 (am. ... Coopers & Lybrand Ltd. (4.02(22)). In fact, 55 of Admiral's employees at Cambridge, Ontario sued Coopers & Lybrand Ltd. ...

At this time Oriole engaged the services of D & S Petroleum Consultants Ltd of Calgary to prepare a valuation of Oriole’s assets. ... There was also a deficiency problem in respect of the Blackfoot property which reduced the value of the assets by $400,000; as a result all the items in the transaction — the shares, employment contract and money payments — were renegotiated and all, including the employment contract, were reduced on a pro rata basis. ... Mr Penner, a chartered accountant practising as a partner with Thorne & Riddell in Calgary, was also called as a witness by the appellant. ...

A-Supreme Nursing & Home Care Services Inc. v. The King, 2023 TCC 39 Docket: 2017-689(GST)G BETWEEN: A-SUPREME NURSING & HOME CARE SERVICES INC., Appellant, and HIS MAJESTY THE KING, Respondent.   ... FACTS [1] A-Supreme Nursing & Home Care Services Inc. (the Appellant) places nurses in long-term care facilities and nursing homes (the “Clients”). ... (the “Act ”). B. Background: [4] The Appellant is incorporated under the Business Corporations Act of Ontario, with its head office located in Toronto, Ontario. ...