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.: — 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 ’). ...

This witness identified the document at Tab 1 which was a letter from the Company accountants, Whynot, Maynard & Bent, more particularly, Chris Maynard, which gave instructions to Mr. ... He had no discussion about the 75% – 25% split. He did not discuss any factors with anyone. ... Argument on behalf of the Respondent [114]Counsel for the Respondent argued that the whole issue is whether or not the Appellant was liable under section 323 of the Excise Tax Act (the “ Act ”) for failure by the Company to remit GST in accordance with section 228(2) of the Act. ...

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. ...

& L. Inc. (”PML) was incorporated in Delaware in 1970. At all relevant times, the shares of PML were held by Arizona. ... When the partnership purchased the hotel on December 14, 1984, the purchase price of $125,500,000 was financed as follows: First mortgage to Equitable Life $ 70,000,000 Promissory notes to vendors 33,500,000 Capital from Partnership 22, 000,000 $125,500,000 The partnership as new owner had invested less than 20 per cent of the cost. ... Marsh & McLennan Ltd., [1983] C.T.C. 231, 83 D.T.C. 5180, Ensite Ltd. v. ...

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. ...

Payne, “ The Dichotomy between Family Law and Family Crises on Marriage Breakdown” (1989), 20 R.G.D. 109 at pages 116-17. ... Minister of Employment and Immigration, [1985] 1 S.C.R. 177,17 D.L.R. (4th) 422,14 C.R.R. 13 at pages 206-07 (D.L.R. 459-60, C.R.R. 48-49): Like “liberty”, the phrase “ security of the person" is capable of a broad meaning. ... The intentional exclusion of property from section 7, and the substitution therefor of “ security of the person" has, in our estimation, a dual effect. ...

[Translation]; (j) The amount of $175,336.71 claimed by the appellant as so-called “ incidental expenses" [Translation] does not represent expenses which it incurred during its 1982 taxation year, but rather represents various expenses which were incurred and paid by the initial promoters of the project between June 25,1982 and December 15, 1982, the whole before the appellant became owner of an interest in the said project; (k) The amount of $175,336.71 was included in the price of $1,775,698.76 mentioned in subparagraph (f) above; (1) The so-called“ incidental expenses" [Translation] claimed by the appellant in 1982 represent the following items: Incidental expenses for the entire project (including the $937,474.20 amounts appearing in Appendix A under the first, second, x 7.57% third, fourth, fifth and sixth claim headings) $72,654.25 Interest paid to the Caisse de dépôt et de placement at the rate of 19 per cent on sums advanced prior to the appel lant’s participation: 102,682.46 lant's participation: TOTAL 175,336.71 [Translation.] 3. ... So what you do in firming up a project like that is to manage to make attitudes change so that people get closer and closer to an agreement, then say, ” Yes, we’ll do it.” ... (S.N. pages 86-87) [Translation] 4.16 On August 4, 1983, an agreement was reached between Cadev, 102077 and 1849 and the group of investors having acquired an interest in the Rockland project from Cadev, that is the appellant, La Laurentienne Mutuelle d'assurance (hereinafter called "La Laurentienne") and the Montreal Police Benevolent and Pension Society (hereinafter called the “ Police Society") (Exhibit A-5). ...

She identified Exhibit R-6, a letter signed by the appellant on Cowling & Henderson letterhead, Barristers and Solicitors, but she felt that she was dealing with the appellant as a person in authority in the Company and not as its lawyer. ... Metropolitan Police Force, 45 D.L.R. (4th) 318 (S.C.C.) and Matheson & MacMillan Ltd. v. ... & P.E.I.R. 189 at page 194 (P.E.I.S.C.) as authority. On the main issue of due diligence or reasonable care under subsection 227.1(3), the Minister says that the Company should have kept a separate account as in James V. ...