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Commissioners of Inland Revenue v Gardner Mountain & D’Ambrumenil Ltd, (1947) 29 TC 69 2. ... Amounts to be included as income from business or property. (1) There shall be included in computing the income of the taxpayer for a taxation year as income from a business or property such of the following amounts as are applicable: (b) Amounts receivable in respect of services, etc, rendered — any amount receivable by the taxpayer in respect of property sold or services rendered in the course of a business in the year, notwithstanding that the amount or any part thereof is not due until a subsequent year, unless the method adopted by the taxpayer for computing income from the business and accepted for the purpose of this Part does not require him to include any amount receivable in computing his income for a taxation year unless it has been received in the year and for the purposes of this paragraph, an amount shall be deemed to have become receivable in respect of services rendered in the course of a business on the day that is the earlier of (i) the day upon which the account in respect of services was rendered, and (ii) the day upon which the account in respect of those services would have been rendered had there been no undue delay in rendering the account in respect of the services. ...

One thing that has happened though — the market is Still fairly conservative, in that the photography that is most often bought is that which is most established, so the older the photographer is and the longer the photographer has been exhibiting and the more reviews and publicity the photographer has, the more that work is being purchased, because it is bought often by corporate collectors and individual collectors as an investment.” ... (SN p 83) (c) “... It takes a great deal of exposure and education for people to become accustomed to unknown artist’s work to start with... they need the support of continuing exhibitions and continuing visual exposure to accept work, and that is the reason for the lack of sales. ...

The Facts 3.01 The only witness for the appellant was Mr Raymond J Connors, CA, a member of the firm Touche Ross & Co and co-executor and trustee of the last will of Mrs Viola Louise Campbell. ... If it is required, those provisions shall be quoted in the analysis. 4.01.2 Counsel for both parties also referred to: (a) The City of St John’s Act (consolidation 1952) Section 2 — definition of “Building Lease” “Building Lease” shall mean, with reference to leases made after August 2nd, 1921, a lease of a vacant piece of land on which the lessee covenants to erect a building or to pull down an old building and erect a new one on the site; and, with reference to leases made before August 2nd, 1921, shall mean a lease of a vacant piece of land on which the lessee or his assigns has erected a building or has pulled down an old building and erected a new one, and shall include any extension of an original lease whether the extension is expressed to be an extension or not of the said original lease. ...

Mr Horta, who was the field supervisor of Sargent while he was in its employ (and there was some confusion here), suggested that he completed his work through a limited company which he had incorporated, namely, Development Control & Planning Ltd (hereinafter referred to as “Development”). ... Two other cases, both in the Federal Court — Trial Division, were referred to: The Queen v Robert B Atkins, [1975] CTC 377; 75 DTC 5263, a decision of Collier, J; and, Francis Lorenzen v The Queen, [1981] CTC 377; 81 DTC 5251, a decision of Mr Justice Grant. ...

M if “Yes” (Name in full including all given names and surname (Please Print): ((Dr RICHARD JOHN HAYES ((Mailing Address (Home): 52 Thursfield Cres, Toronto M4G 2N5 (Birth Date Nov 6, 1946 Sex M Social Insurance No 454 067 244 UNIVERSITY OF TORONTO SCHOOL OF CONTINUING STUDIES 158 St George Street Toronto, Ontario, Canada M5S 2V8 (416) 987-2400 COURSE ARRANGEMENTS WITH R J Haynes Course Number SCSOOOB Course Name Computer Concepts & Applications Description of Assignment Term Sessions Day Dates Time Hours Location Fall 12 Tues Sept 21-Dec 7 6:30-9:00 pm 2 21/2 Room 243 Winter 8 Jan 4-Feb 22 Galbraith Spring Summer Total 20 Total 50 Term Stipend $36 per hr Vacation pay included Total $1,800 Fall $1,080 Winter 720 Spring Summer Total $1,800 Please adhere to these arrangements unless you have secured the co-ordinator’s agreement to any proposed change. ... —As to the specific other party contracting with Haynes, it can only be the U of T—the appellant received his remuneration only from U of T, none from the SIA or from ICB directly. — U of T had the contracts for service with ICB and SIA, and it was for U of T to fulfill these under its own discrection. ...

Paragraphe 212(5)—Français 212.(5) Toute personne non résidante doit payer un impôt sur le revenu de 25% sur toute somme qu’une personne résidant au Canada lui verse ou porte à son crédit, ou est réputée, en vertu de la Partie I, lui verser ou porter à son crédit au titre ou en paiement intégral ou partiel d’un droit d'utilisation ou autre sur (a) un film cinématographique, ou (b) un film ou une bande magnétoscopique pour la télévision, que a été utilisé ou reproduit au Canada, ou doit l’être. 5.3.5 According to the English version (“... payment for a right in or to the use of...”) it seems, at first glance, that because of the word “right” construed in its broadest sense one could conclude that it includes a “right of ownership”, and hence the sale of a motion picture. ... It seems that the provision is restricted to payment for rights in a picture only, the effect of drafting being to exclude an outright sale of the motion picture itself. 5.3.6 The French text (“... en paiement intégral ou partiel d’un droit d’utilisation ou autre sur...”) seems, at first glance, to arrive at the former conclusion. ...

.: — This is an appeal from a judgment of the Trial Division, pronounced on May 18, 1995, which set aside a determination by the Minister of National Revenue that excise tax paid by the respondent, Canadian Turbo, on the sale of gasoline and diesel fuel was not refundable. ... (London: Sweet & Maxwell, 1977); Bryan A. Garner, A Dictionary of Modern Legal Usage, 2nd ed. ...

.: — These appeals, brought by way of the informal procedure, were heard on common evidence. ... On this aspect, I refer to what is stated by Gonthier J. at page 250 (D.T.C. 5022): … At page 87 of his text Construction of Statutes (2nd ed. 1983), Driedger fittingly summarizes the basic principles:... ...

.: — Gilvesy Enterprises Inc. appeals from reassessments whereby the Minister of National Revenue (the Minister) reduced the amount of its claim for an allowable business investment loss (ABIL) in the 1987 taxation year, and included in its income certain amounts as deemed interest under subsection 17(1) of the Income Tax Act (the Act) for each of the 1987, 1988 and 1989 taxation years. ... Campbell, The Valuation & Pricing of Privately-Held Business Interests,(Toronto: CICA, 1990) page xxxvii 6 See Canada (National Capital Commission) v. ...

.: — The appellant appeals from assessments of income tax for the 1985, 1986 and 1987 taxation years. ... Design # of times used in Processing area as building restaurants in issue a percentage of total building BK90 11 53.72 BK92 9 38.79 BK22 7 49.16 BKSOXL 4 45.72 BK120 6 56.12 Image 87 [3] 7 45.73 BKSOL 4 49.30 48 Neither counsel suggested that success be divided on the basis that the processing portion of the floor area of some buildings is greater than 50 per cent and of others is less. ...