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Grandin Park Barber Shop & Beauty Parlour LTD v. Minister of National Revenue, [1984] CTC 2121, 84 DTC 1071 Sarchuk, TCJ:—Grandin Park Barber Shop & Beauty Parlour Ltd. ... Subsequently on April 26, 1978 the appellant acquired a 34 per cent undivided interest in a parcel of land in Caroline, Alberta, described as Pt NE 1/4 — 13 — 36 — 6 — W — SthM (the “Caroline property”) for a price to the appellant of $40,800. ... The Concise Oxford Dictionary defines replace at page 951: replace — “Put back in place; take place of, succeed, be substituted for; (in pass) be succeeded or have one’s or its place filled by, be superseded; fill up place of (with, by), find or provide substitute for.” and substitute at page 1151: substitute — “1. ...

Weisz, Rocchi & Scholes v. The Queen, docket 2000-4221-IT-I (Informal Procedure) Date: 20010327 Docket: 2000-4221-IT-I BETWEEN: WEISZ, ROCCHI & SCHOLES, Appellant, and HER MAJESTY THE QUEEN, Respondent. ... It is sufficient to say that the due date for making the November 1999 remittance was December 15, 1999. [5]            Subsection 248(7) reads:                 For the purposes of this Act, (a)            anything (other than a remittance or payment described in paragraph (b)) sent by first class mail or its equivalent shall be deemed to have been received by the person to whom it was sent on the day it was mailed; and (b)            the remittance or payment of an amount                 (i)             deducted or withheld, or                 (ii)            payable by a corporation,                 as required by this Act or a regulation shall be deemed to have been made on the day on which it is received by the Receiver General. [6]            The remittance of payroll deductions with which we are concerned here falls under paragraph (b) of that provision. [7]            It is admitted that the remittance was mailed to the CCRA on December 8, 1999 in the window envelope together with a self-addressed remittance stub provided by the CCRA. ... It is particularly indefensible where the facts upon which the penalty is imposed — in this case the alleged late receipt of a remittance — are entirely within the Minister's possession. ...

Highweb & Page Group Inc. v. The Queen, 2015 TCC 137 (Informal Procedure) Docket: 2014-1703(IT)I BETWEEN: HIGHWEB & PAGE GROUP INC., Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... Introduction and Issues [1]              The Appellant, Highweb & Page Group Inc. ... Her Majesty The Queen, 2006 TCC 597 (“ Zeuter Development ”) at paragraph 26. ...

The 44 workers concerned are as follows: Audy, Michel                                                  Lampron, Sylvain Béland, Michel                                                                Ledoux, Francis Benoit, Claude                                                                 Leduc, Benoit Blanchard, Claude                                                           Lévesque, Alain Blanchette, François                                       McCraw, Kim Bonneville, Marcel                                                          McLaughlin, Sylvie Bourassa, Mario                                                              Martineau, Serge Brien, Mathieu                                                                 Meunier, Claude Charron, Martin                                                               Migneault (Mignot), Julie Chartrand, Jacques                                                         Moisan, Hélène Cornescu, Horia                                                              Nicolas, Michel Desmarais, Richard                                         Pérusse, Gabriel Dion, Joane                                                      Pilon, Martin Doré, Daniel                                                     Proulx, Eddy Dufour, André                                                                 Provencher, Marc Forget, Normand                                                             Rhéaume, Bruno Gadoua, Pierre                                                                 St-Jean, Daniel Hébert, Denis                                                   Tanguay, François Hudon, Julie                                                     Tessier, Jenny Jacob, Lyne                                                      Vachon, Jean-Pierre Laliberté, Guy                                                  Vanier, Luc Lamontagne, René                                                          Vanier, Pierre [3]            In reaching his decision in this case, the Minister relied in particular on the following assumptions of fact, of which the appellant company either admitted or denied the truth:                                 [TRANSLATION] (a)            The appellant is a company that produces children's television programs. ... He added that he did not construct any sets in 1998. [90]          Mr. ... and The Minister of National Revenue PLACE OF HEARING:                                         Montréal, Quebec DATES OF HEARING:                                         November 19, 20, 21, 22 and 23, 2001 REASONS FOR JUDGMENT BY:      The Honourable Judge François Angers DATE OF JUDGMENT:                                       November 6, 2002 APPEARANCES: For the Appellants:                                               Roch Guertin For the Respondent:                             Stéphane Arcelin                 For the Intervener:                                                The Intervener himself COUNSEL OF RECORD: For the Appellants:                                 Name:                      Roch Guertin Firm:                                        Montréal, Quebec For the Respondent:                             Morris Rosenberg                                                                                                 Deputy Attorney General of Canada                                                                                 Ottawa, Canada 2000-3683(EI) BETWEEN: LES PRODUCTIONS PETIT BONHOMME INC., Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent. ...

Brian & Deborah Dewan Enterprises Ltd. v. The Queen, 2017 TCC 135 (Informal Procedure) Docket: 2016-5262(GST)I BETWEEN: BRIAN & DEBORAH DEWAN ENTERPRISES LTD., Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... “Johanne D’Auray” D’Auray J.   Citation: 2017 TCC 135 Date: 20170719 Docket: 2016-5262(GST)I BETWEEN: BRIAN & DEBORAH DEWAN ENTERPRISES LTD., Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... The appellant did not collect and remit GST/HST on the sales of the limousines, which amounted to $13,741.00. [3]              In this appeal, the provision applicable is section 141.1 of the Excise Tax Act (“ Act ”). ...

As a result, the employment of each worker was insurable employment for the purposes of the Act. [3]   In making his decisions, the Minister considered the following facts in paragraph 16 of the Reply to the Notice of Appeal: (a) the appellant is an incorporated entity; (b) the appellant operates a PVC window and door sale and manufacturing business; (c) during the period at issue, 9073-3965 Québec Inc. held and controlled all of the appellant’s voting shares; (d) during the period at issue, Josée Bilodeau held and controlled all the voting shares of 9073‑3965 Québec Inc.; (e) Josée Bilodeau is the mother of the workers; (f) the appellant had six directors responsible for: (i) Sales; (ii) Field sales; (iii) The two factories; (iv) Purchasing; (v) Shipping; and (vi) Human Resources; (g) Bianca Dupuis was the Purchasing Director; (h) Bianca Dupuis looked after: (i) sales customer service; (ii)   price changes; (iii)   marketing brochures; and (iv)   the computer system; (i) Catherine Dupuis was Director of Human Resources; (j) Catherine Dupuis looked after: (i) hiring and terminations; (ii)   employee complaints; (iii)   training; (iv)   health and safety; and (v)   social events; (k)   Jonathan Dupuis was the Director of the appellants’ two factories; (l)   Jonathan Dupuis looked after: (i)   purchasing machinery and trucks; (ii)   product research and development; (iii)   supervising team leaders; and (iv)   replacing missing staff; (m)   Samuel Dupuis was: (i)   a day labourer until August 2016; then (ii)   replacement team leader since August 2016; (n)   As a day labourer, Samuel Dupuis worked on the door and window assembly line; (o)   As a replacement team leader, Samuel Dupuis supervised 10 to 15 employees working in one of the appellant’s two factories; (p)   the appellant remunerated the workers by direct deposit for services rendered; (q)   the appellant made deductions at source from the workers’ pay; (r)   the workers met regularly with Josée Bilodeau to discuss work; (s)   the appellant retained her right of supervision; (t)   the appellant issued T4 slips to the workers; (u)   the workers were paid at different hourly rates depending on their position and seniority; (v)   workers were paid overtime when they worked more than 40 hours a week; (w)   during part of the period at issue, Jonathan Dupuis was paid a fixed weekly salary; (x)   while Jonathan Dupuis was paid a fixed weekly salary, the additional hours he worked were banked and converted to leave; (y)   the appellant paid the workers annual bonuses because they performed additional duties; (z)   with the bonuses they received, the workers’ salaries were in line with the market average; (aa)   the workers had not completed post-secondary studies; (bb)   the workers gained experience over the years, working for the appellant; (cc)   the workers completed timesheets, as did the other employees working for the appellant; (dd)   the workers were covered by the appellant’s group insurance, as were the other employees working for the appellant; (ee)   the workers accrued vacation days based on their seniority; (ff)   the workers worked for the appellant full-time for several years; (gg)   as experienced, reliable and responsible workers, they had a somewhat flexible work schedule; (hh)   as persons working in management positions, the workers worked a few hours without asking for remuneration; (ii)   the workers mostly worked in the appellant’s place of business; (jj)   as workers in management positions and/or workers who did not have to use heavy equipment, they worked a little from home; (kk)   the appellant paid for certain expenses when the workers worked outside the area; (ll)   the appellant operated year‑round; (mm)   the workers were hired year‑round; (nn)   the duties performed by the workers were essential to the appellant’s activities; and (oo)   none of the workers received extravagant or overly generous terms of employment, based on their position in the company. [4]   At the hearing, the agent for the appellant admitted that a contract of service existed between the appellant and each worker. ... CITATION: 2019 TCC 96 DOCKET: 2017-4148(EI) STYLE OF CAUSE: PORTES & FENÊTRES ABRITEK INC. ... Drouin Deputy Attorney General of Canada Ottawa, Canada     ...

& D. H. Holdings Limited v. Minister of National Revenue, [1986] 2 CTC 2364, 86 DTC 1730 Taylor, T.C.J. ... This amount was calculated by the Respondent as follows: Milk Quotas Other Assets Total Total Proceeds $1,600,000.00 $1,094,700.00 $2,694,700.00 Adjusted Cost Base 1,000,000.00 515,000.00 1,515,000.00 Excess $ 600,000.00 $ 579,700.00 $1,179,700.00 Section 14 — Proceeds (12) $ 300,000.00 $ 289,850.00 $ 589,850.00 Milk Quotas Other Assets Total Total Opening Balance Accumulative Eligible Capital $ 1,579.00 Nil $ 1,579.00 Revised Negative Accumulative Eligible Capital $ 298,421.00 $ 289,850.00_$_ 588,271.00 Deduct: Amount reported Nil $ 289,850.00 $ 289,850.00 Increase reassessment $ 298,421.00 Nil $ 298,421.00 (cc) the Appellant acquired shares of Robbinex Trading Corporation (hereinafter 'Robinex’) from its parent company’s shareholders for $700,000 on or about January 1, 1981. ... The butter might be stored on the premises of the appellant — at the option of the C.D.C. — but that in no way altered this elementary situation. ...

Canadian Security & Mobile Patrol Services Ltd. v. M.N.R., 2023 TCC 34 Dockets: 2019-3371(EI) 2019-3372(CPP) BETWEEN: CANADIAN SECURITY & MOBILE PATROL SERVICES LTD., Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent.   ... “Patrick Boyle” Boyle J.   CITATION: 2023 TCC 34 COURT FILE NO.: 2019-3371(EI) 2019-3372(CPP) STYLE OF CAUSE: CANADIAN SECURITY & MOBILE PATROL LTD. ... PLACE OF HEARING: Toronto, Ontario DATE OF HEARING: March 13, 2023 REASONS FOR JUDGMENT BY: The Honourable Justice Patrick Boyle DATE OF JUDGMENT: March 22, 2023 APPEARANCES:   Agent for the Appellant: Hasan Shahid Counsel for the Respondent: Amin Nur   COUNSEL OF RECORD: For the Appellant: Name:     Firm:   For the Respondent: Shalene Curtis-Micallef Deputy Attorney General of Canada Ottawa, Canada     ...

& V.) and Heppell & Bouchard Inc. (hereinafter referred to as H. ... The eight parties to the contract were as follows: — Heppel & Bouchard Inc.; — Robert Verrier & Fils Ltée; — La Royale du Canada, Cie d'assurance; — La Compagnie d'assurance du Québec; — Gestions H. & B. Ltée; — Les Placements Claude Bouchard; — Claude Bouchard; — Michel Verrier. ...

If the framers of the Regulation had intended to mean the business itself, they would have used the word " thereby " or " by it " rather than the word " therein ", which latter word conveys the sense of being inside something physical. In the same vein the word " therein " can hardly apply to personnel. ... " is a hairdressing salon operating in the City of Edmonton ". ...