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It being a taxable Canadian property, the appellant, in so doing, realized a taxable capital gain of $361,151, as follows: Taxable capital gain $669,772 x 1/2 x 182/362 days $256,089 Plus $669,772 X 2/3 X 56/238 days $105,062 Taxable capital gain $361,151 (c) During the relevant taxation years, the appellant also did not operate a business in Canada, but instead derived income from property here; (d) For the purposes of section 115 of the Income Tax Act, the taxable income which the appellant earned in Canada during its 1988 taxation year was $361,151, as follows: Taxable capital gain $361,151 Loss from the year or from a previous year from a business operated in Canada — — Taxable income $361,151 (e) For the purposes of section 216 of the Income Tax Act, the taxable income of the appellant for its 1988 taxation year is nil, the latter having derived an income from property equal to zero during that same taxation year. ...

The Minister of National Revenue (the "Minister") disallowed the claim for an ABIL because the loss did not fall within the provisions of paragraph 39(1)(c) of the Income Tax Act (the " Act ") as it had been incurred by a trust under circumstances where the provisions of subsections 104(1) and 104(2) of the Act did not apply so as to permit her to deduct losses sustained by the trust or to have the loss attributed to her pursuant to subsection 75(2) of the Act. [2] The appellant testified she works in the field of investments and has invested in mortgages personally as a means of generating income. ...

One hired the other to work for the other business during the period in issue. [58] It is highly suspicious that this was a work exchange program and the Court has to look at the evidence “ in toto ” in order to decide whether that is the case. ...

The Appellant is a charity registered under the Excise Tax Act (" Act "). ...

(Exhibit A-30) was registered on the date of supply and this assessment is correct. [17] Subsection 165(1) of the Excise Tax Act (" ETA ") reads: 165(1) Subject to this Part, every recipient of a taxable supply made in Canada shall pay to Her Majesty in right of Canada tax in respect of the supply calculated at the rate of 7% on the value of the consideration for the supply. ...

The following comment on the rule appears in “ The Law of Evidence in Civil Cases ” by Sopinka and Lederman, Butterworth 1974: Although the rule is still referred to with respect to matters other than the admission of secondary evidence of documents, it is rather by way of a rationale for assigning less weight to the evidence tendered than as a reason for its exclusion. ...

Currently, the contribution is equal to the required maximum of ½ of 1% of basic payroll. 6. ... But the Long Term Disability Plan (which is exclusively funded by the employees – 19.11.4) is an insurance plan with The Mutual Life Assurance Company of Canada. ...

., hereinafter referred to as "the Company", for the period August 28, 1997 to August 28, 1998, within the meaning of the Employment Insurance Act, hereinafter referred to as the " Act ". ...

He also admitted that the tables were the determining factor in his recommendations. [25] The work performed by the appellants was excepted from insurable employment under paragraph 3(2)(c) of the Unemployment Insurance Act (“the Act ”). ... Bayside Drive-In Ltd., A-627-96; Ferme Émile Richard & Fils Inc. v. ...

I would point out that that document differs in a few respects from a document found at Tab 1 of Exhibit A-1. [... ... Erich Klein, Revisor [1]            One might add: or is practising an unrelated profession. ...