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SARJI Plaintiff- and- MINISTER OF NATIONAL REVENUE (Customs & Excise) Defendant REASONS FOR ORDER INTRODUCTION LEMIEUX J.: (1]        Ahmad A. ... She was wearing several pieces of jewellery.          They were visible.    ... THE MINISTER OF NATIONAL REVENUE (CUSTOMS & EXCISE) PLACE OF HEARING:                MONTRÉAL, QUÉBEC DATE OF HEARING:                   MARCH 16, 1999 REASONS FOR JUDGMENT OF THE HONOURABLE MR. ...

Richard, for the responend MacMillan & Bloedel (Alberni) Ltd. J. B. ... Solicitors for the respondent, MacMillan & Bloedel (Alberni) Ltd.: Gowling, MacTavish, Osborne & Henderson, Ottawa. Solicitors for the respondent, Ontario-Minnesota Pulp & Paper Ltd.: Fraser, Beatty, Tucker, Mclntosh & Stewart, Toronto. ...

. — 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? ...

Front & Simcoe, Limited v. Minister of National Revenue, [1960] CTC 123, 60 DTC 1081 CAMERON, J. ... Secondly, a transaction which, on its true construction, is of a kind that would escape tax is not taxable on the ground that the same result could be brought about.by a transaction in another form which would attract tax. ’ ’ The question for determination, therefore, is ‘‘ What is the real character of the receipt?’’ ... C.I.R., 12 T.C. 1955, and similar cases. ’ ’ In the instant case, the appellant company retained the full ownership of its only capital asset—the Barclay Hotel. ...

(“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. ...

Canadian Industrial Gas & Oil Ltd. v. Government of Saskatchewan et al., 80 DLR (3d) 449, [1978] 2 S.C.R. 545 Supreme Court of Canada Canadian Industrial Gas & Oil Ltd. v. ... The concept originated with Holmes J. in Swift & Co. v. United States [40]. It was applied in Stafford & Wallace [41] and in Chicago Board of Trade v. ...

A I don’t know whether I can answer you that directly — you know — everything that one does in business today — you have the two (2) facets: one is the operations, and the other is the financial, if you want, and it is very complex, especially to a person such as myself, and I do depend upon professional counsel. ... Q A fair assumption — there would be no problem with these preferred shares?... ... Alpine Drywall & Decorating Ltd v MNR, [1966] CTC 359; 66 DTC 5263; 6. ...