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Tusket Sales & Service Limited v. The Queen, docket 1999-5124(GST)I (Informal Procedure) Date: 20000727 Docket: 1999-5124-GST-I BETWEEN: TUSKET SALES & SERVICE LIMITED, Appellant, and HER MAJESTY THE QUEEN, Respondent. Reasons for Judgment Hamlyn, J.T.C.C. [1]            This is an appeal with respect to an assessment under Part IX of the Excise Tax Act (the " Act ") for the period January 1, 1993 to February 29, 1996, by Notice of Assessment No. 01CB0202152 dated July 17, 1996. [2]            The Appellant is a corporation involved in the sale of new and used motor vehicles. [3]            Between 1994 and 1995, the Appellant sold 14 vehicles to one Vaughn Pictou ("Pictou"), a status Indian. ... Pictou indicating that GST was paid; 6(i)           at no time did Mr. ...

Dow & Duggan Log Homes International (1993) Limited v. The Queen, 2019 TCC 280 Docket: 2017-2928(GST)G BETWEEN: DOW & DUGGAN LOG HOMES INTERNATIONAL (1993) LIMITED, and HER MAJESTY THE QUEEN, Respondent.   ... Factual background – Deposits and work-in-progress [59]   With respect to work-in-progress, Mr. ... Drouin Deputy Attorney General of Canada Ottawa, Canada     ...

A & D Precision Limited v. The Queen, 2019 TCC 48 Docket: 2014-3465(IT)G BETWEEN: A & D PRECISION LIMITED, Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... Russell” Russell J.   Citation: 2019TCC48 Date: 20190228 Docket: 2014-3465(IT)G BETWEEN: A & D PRECISION LIMITED, Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... Introduction: [1]   This is a scientific research & experimental development (SR&ED) case. ...

. — Impenco Ltee v. Minister of National Revenue, [1988] 1 CTC 2339, 88 DTC 1242 Couture, C.J.T.C. ... It was established in cross-examination that between 1981 and 1986 the appellant had the following gross and net income and made these contributions to charitable organizations: Gross Income Net Income For Charitable Donations Tax Purposes 1981 $4,026,113 $ 82,507 1982 5,186,382 $ 546,597* [1] 104,226 1983 6,436,017 1,154,097 * 186,115 1984 4,577,312 456,065 178,097 1985 5,472,160 368,288* 186,307 1986 5,279,177 388,395 188,985 Mr. ... In Olympia Floor & Wall Tile v. M.N.R., [1970] C.T.C. 99; 70 D.T.C. 6085 Jackett, P. ...

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. ...

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. ...

Procon Mining & Tunnelling Ltd. v. The Queen, 2022 TCC 71, aff'd 2024 FCA 1 Docket: 2017-4641(IT)G 2019-2446(IT)G BETWEEN: PROCON MINING & TUNNELLING LTD., Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... The other issuer’s press release also describes Procon’s acquisitions of its shares as an “ Investment by Procon” and similarly describes Procon having agreed to acquire the shares “ for investment purposes ”. 5) The Book of Documents includes another press release of one of the issuers indicating that, in addition to Procon acquiring its shares, Mr. ... Canada (Minister of National Revenue — M.N.R.), [1967] 1 Ex. C.R. 245 at p. 257. ...

& Candor Investments Ltd. v. Minister of National Revenue, [1989] 2 CTC 2076, 89 DTC 355 Kempo, T.C.J. ... May 1978 “Keg Building” 605-11th Avenue S.W., Calgary — Renovate and rent. b. ... Fall 1978 to mid 1979 "Petro Canada Land" 101-6th Avenue S.W., Calgary — Land accumulation/assembly — Redevelopment project. d. ...