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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. ...

(“Posi-Line”)) appeals from an assessment of $71,782.25, pursuant to subsection 227.1(1) of the Income Tax Act (the “Acf ’). ... For Stone Laurie & Company to prepare a financial statement for a fiscal year end of August 31, 1989 and noting that it was a change, I would assume that they would have required a resolution of the board of directors, dated sometime prior to August 31, 1989, changing the year end, or they would have in their review engagement report to the shareholders dated November 23, 1989, have brought up the necessity of proper corporate procedures to be carried out to effectively change the corporate fiscal year end. ...

NO — Severe osteoarthritis of hips requiring replacement. Can your patient walk 100 metres on level ground (1 block) with an aid? ... NO — Uses canes but able to walk only sometime (sic). This answer was given on August 28, 1994. ...

. /?.,(! 983), 83 D.T.C. 5388 (Fed. T.D.) at page 5392 indicating that there need only be one transaction so long as the transaction is of the same kind and is carried out in the same way as that of an ordinary trader. ... “Wilful blindness by someone capable of acting in a responsible manner is not a matter of ‘ignorance of the law’ in its jurisprudential sense — it can amount to gross negligence in appropriate circumstances.” ...