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They are: (a) the existence of a common mind which directs the bargaining for both parties to the transaction, (b) parties to a transaction acting in concert without separate interests, and (c) " de facto " control. ... " [31] This approach was also adopted by Cullen, J. in the case of Peter Cundill & Associates Ltd. v. ... Part 2 – Review of the Evidence as it relates to Kevin Sharp and Brian Sharp [88] I do not propose to review all of the evidence a further time. ...

Fleming & Co. (Machinery), Ltd. (1951), 33 T.C. 57 (Ct. of Sess.). 0997_5941_6143 3 See e.g., The Glenboig Union Five Clay Co., Ltd. v. Commissioners of Inland Revenue (1922), 12 T.C. 427 (H. of L.) at 39-40; Barr, Crombie & Co., Ltd. v. ... See Barr, Crombie & Co., Ltd. v. C.I.R., [1945] S.C. 271; 26 T.C. 406 at 411 (Scot.), Fleming, supra, at page 63. ...

& M. Johnson Contracting Ltd. v. The Queen, docket 96-4072-IT-G Date: 19980515 Docket: 96-4072-IT-G BETWEEN: A. & M. JOHNSON CONTRACTING LTD., Appellant, and HER MAJESTY THE QUEEN, Respondent. ... Subsection 152(6) seems to impose some obligation on the Minister because the operative clause begins with the words “the Minister shall reassess... ”. ...

Each case stands on its own merits. [5]      In making his decision, the Minister relied on the following assumptions of fact: [TRANSLATION] (a)         The appellant was incorporated on July 1, 1995, as a result of a merger between Groupe Desmarais Inc. and Assurances Pinsonneault, Avard, Paré Inc.; (b)         The appellant's capital stock is distributed as follows:            - Gestion A.C.D. Inc. holds 60% of the voting shares;            - Yvon Pinsonneault holds 20% of the said shares; and            - Martin Avard holds 20% of the said shares; (c)         The capital stock of Gestion A.C.D. ... Watson Appearances Counsel for the Appellant:                             Rock Guertin Counsel for the Respondent:                         Dany Leduc JUDGMENT           The appeal is allowed and the Minister's decision vacated in accordance with the attached Reasons for Judgment. ...

R & S Industries Inc. v. The Queen, 2017 TCC 75 Docket: 2014-3997(IT)G BETWEEN: R & S INDUSTRIES INC., Appellant, and HER MAJESTY THE QUEEN, Respondent.     ... Costs of the motion shall be in the cause.   The Respondent shall file a reply on or before June 30, 2017.   ... Graham” Graham J.   Citation: 2017 TCC 75 Date: 20170505 Docket: 2014-3997(IT)G BETWEEN: R & S INDUSTRIES INC., Appellant, and HER MAJESTY THE QUEEN, Respondent.   ...

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. ...

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. ...

BUREAU BARRISTER & SOLICITOR INCORPORATED, Applicant, and HER MAJESTY THE QUEEN, Respondent.   ... Except as otherwise indicated, statutory references herein are provisions of the ETA. [2]   Under the marginal heading, “When order to be made”, subsection 305(5) provides: (5)   No order shall be made under this section unless (a)   the application is made within one year after the expiration of the time otherwise limited by this Part for appealing; and (b)   the person demonstrates that (i)   within the time otherwise limited by this Part for appealing, (A)   the person was unable to act or to give a mandate to act in the person’s name, or (B)   the person had a bona fide intention to appeal, (ii)   given the reasons set out in the application and the circumstances of the case, it would be just and equitable to grant the application, (iii)   the application was made as soon as circumstances permitted it to be made, and (iv)   there are reasonable grounds for appealing from the assessment. [3]   The respondent asserts that the following four requirements specified in subsection 305(5) were unmet: subparagraph 305(5)(b)(i) – the applicant must demonstrate that within the 90-day period for appealing … it had a bona fide intention to appeal; subparagraph 305(5)(b)(ii) – given the reasons set out in the application and the circumstances of the case, it would be just and equitable to grant the application; subparagraph 305(5)(b)(iii) – the application was made as soon as circumstances permitted; and subparagraph 305(5)(b)(iv) – there are reasonable grounds for appealing … Factual overview: [4]   At the hearing, an amended affidavit of Canada Revenue Agency (CRA) officer S.  ... Drouin Deputy Attorney General of Canada Ottawa, Canada     ...

& F. and Sumas, dated April 16, 1981. Exhibit A-6 — Form letter from M. ... & F. The "distribution rights’ applied to a larger area — all of Canada — and indeed export markets (see Exhibit A-5). ... & F., so that M. & F. had no further involvement with that company. ...

Appeal of R & L Investments Ltd. These are the matters in dispute regarding R & L Investments Ltd. ... The allocation of the $19,008.66 to taxation years is 1981 — $6,892.08, 1982 — $6,400.37 and 1983 — $5,716.21. ... The selling broker was Murdock & Maber Agencies Ltd. and it issued a receipt for $5,800 to R & L. ...