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The purchase price per unit shall be allocated between the common shares and the warrants comprising each unit at $100,000 and $80,000, respectively. 2.2 Payment of Subscription Price The subscriber encloses with this agreement a cheque in the amount of $360,000 drawn on the trust account of the subscriber’s solicitors, Woolley, Dale & Dingwall, and made payable to the Trustee. 2.3 Escrow The parties hereto acknowledge that the payment made pursuant to section 2.2, less the $160,000 loan provided in the loan agreement [4] and the legal fee of $10,000 provided for in section 8.1, shall be held in escrow by the trustee until the company has satisfied all conditions of subscription set out in Article VI. If such conditions have not been satisfied to the satisfaction of the subscriber and his counsel by the close of business (Calgary time) on January 16, 1987, the company shall forthwith direct the trustee to forward the subscription funds, less the $160,000 loan provided in the loan agreement, to Woolley, Dale & Dingwall. ... Disbursement of Funds: Upon execution of this agreement, the Trustee shall issue a cheque to your solicitors, Woolley, Dale & Dingwall, in trust, in the amount of $160,000. 9. ...

Spackman stated that ”... there was a lot of time spent coming to grips with that issue and the details of who was entitled to what and getting everybody to agree on that". ... She pointed to work done to reduce taxes on capital gains deemed to have been realized on death and submitted that the ability of the trust to earn income ”... was largely dependent on Mr. ... Such fees, she said, ”... did not bring anything into existence." She relied on the decision of the Supreme Court of Canada in Premium Iron Ores Ltd. v. ...

Its bookkeeping was done in Toronto and Coopers & Lybrand's Toronto office managed its audit. ... This is reflected in a letter (Exhibit R-3) dated October 23,1981 in which Quinton, the secretary-treasurer of the appellant, reported a transaction to its accountants, Coopers & Lybrand (Exhibit R-3) in the following words: Late in 1980 it became clear that the market would not support both Simon- Carves Inc. and Allen & Garcia and it was decided to close down the former. ...

And secondly, the respondent argues that the truck is not used in Canada primarily for the purpose of operating an oil or gas well within the meaning of subparagraph 127(10)(c)(ii); and, therefore, the truck is not “ qualified property”. ... Urie, J.A. delivered the unanimous judgment of the Court and stated, at page 426 (D.T.C. 6319): While perhaps initially the vehicles used by the respondent were “ designed for use on highways or streets" their design was so modified for purposes of their utilization, that the limited design purpose was of minimal importance. ... Accordingly, the hot oil unit is “ qualified property" within subsection 127(10). ...

Statement of Proprietary Information In accordance with the conditions of the RADARSAT Contract between SPAR Aerospace and COM DEV, S-700014, Article 12 — Intellectual Properties — this will certify that all equipments, associated Technical Information and Technical Documentation to be generated in performance of the Work and considered deliverable under the contract will utilize computer software, processes, methods, techniques and know-how in existence or residence with COM DEV prior to effective date of the Contract. ... To qualify as a contract payment under paragraph (/?) in subsection 127(9), an amount must: 1) be payable by a Canadian government, municipality or other Canadian public authority or by a person exempt from tax under Part I by virtue of section 149; and 2) be payable for SRED be performed for it or on its behalf. ...

(“the Company”), which operated the variety store under the name “M & G Variety Store”. [2] At the time of purchase, Dominic was employed in a grocery store and Rocco was employed as a butcher. ... This document was carefully prepared and entitled “Employment Status- Maria Spagnolo” and sets out: This is to verify the employment status of Maria Spagnolo and M & G Variety from November 27, 1995 to April 26, 1996. In signing, you agree to have seen Maria Spagnolo perform her daily responsibility... as an employee of M & G Variety during the above noted time period. ...

Accordingly, Homebank was at all material times a "Canadian-controlled private corporation" as defined in subsections 248(1) and 125(7) of the Income Tax Act ("the Act "). [5] During 1988, Homebank purchased land located at 930 Upper Paradise Road in Hamilton, Ontario and acted as the prime contractor during construction of a 17 unit strip plaza with approximately 48,000 square feet of gross leasable space. ... M.N.R. [1991] 1 C.T.C. 2245, 91 D.T.C. 364, where Brulé, T.C.J., stated at page 369, that with respect to the definition of "specified investment business" what is meant by "the principal purpose of which is to derive income from property" is "... when the source of revenue, the nature of the assets held and the purpose of the corporation are to derive income from property, such as interest income. [28] In Ed Sinclair Construction & Supplies Ltd. et al. v. ...

., docket 1999-2406-EI Date: 19991214 Docket: 1999-2406-EI; 1999-2408-CPP BETWEEN: CONSUMER CONCEPTS CORPORATION, Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent, Reasons for Judgment Cain, D.J.T.C.C. [1] These are appeals by Consumer Concepts Corporation, hereinafter called the “Appellant”, from a ruling of the Minister of National Revenue, hereinafter called the “Respondent” made after a request from the Appellant for the determination of the question of whether or not Chantal Gelinas, hereinafter called “Worker”, was employed in insurable and pensionable employment while engaged by the Appellant for the period May 23, 1997 to April 9, 1998 within the meaning of the Employment Insurance Act, hereinafter referred to as the “ Act ” and the Canada Pension Plan respectively. [2] At the outset the parties agreed to combine the appeals, to proceed with the appeal relating to employment insurance and then apply the evidence led in that appeal to the appeal relating to the Canada Pension. [3] From the evidence adduced the Court makes the following finding of facts. [4] The Appellant carries on the business of displaying manufacturer’s products in retail settings. ... He would then contact food stores, mostly important chain stores such as Steinberg, A & P, Dominion, Woolco and others to have their consent to his promotion project, which would be beneficial to them. ...

It purchased farm land and farm equipment at prices and on terms as tabulated: Farm Land Farm Equipment 1973 160 acres- $24,000 This land was farmed by his brother-in-law and was paid for by July 31, 1974 from the crop, his wife's teaching and his dental income. 1974 480 acres tractor, pull combine, ½ ton truck with grain box, discer, augers, harrows, swather, cultivator and seeder $60,000 for all of the above, which was borrowed from the Bank of Montreal. 1975 John Deere 4430 tractor $22,500 borrowed from Bank of Montreal 1976 Tandem Disc $6,700. ... The family rented a trailer, put it on the farm land and lived in it for 3 ½ years while they built an energy efficient home on the farm, which is presently valued at approximately $350,000. 1980 160 acres $85,000 Loan from Canadian Imperial Bank of Commerce Quonset package, $24,000 (cash) 1982 TR75 Combine $85,000 loan from New Holland Finance Corp. 1983 John Deere Seeder $18,000 (cash) 1985 Versatile Tractor $109,000 loan from Versatile Finance Corporation 50 ft. Bourgault $32,500 financed by Canadian Imperial Bank of Commerce loan TRNH Combine $77,000* Combine $100,000* Seeder $20,000* * All financed by New Holland Credit The Appellant cashed in his RRSP's and paid off CIBC and Versatile Finance Corp. ...

Cayer and one of his co-workers put it this way: “ We have considered taking control of this operation and maximizing the liquidation process; however, this alternative would expose us to a loss. ... Veilleux for challenging the Minister’s assessment is that he exercised “ the degree of care, diligence and skill to prevent the failure that a reasonably prudent person would have exercised in comparable circumstances ”, as required by subsection 227.1(3) of the Act. ...