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At paragraphs 3 and 4 of his judgment, Létourneau, J.A. stated: "In connection with the control which characterizes master-servant relations in a contract of employment, and thus the relationship of subordination required between the employer and employee, the Tax Court of Canada deputy judge considered inter alia the following facts: (a) Mr. ...

Bruno also included a five per cent risk and illiquidity factor in his adjustments to take into account what an objective and reasonably informed purchaser or investor would want as a return on the capital to be invested in connection with the development of Lot 108, as compared to the return on a safe long-term investment in a secure, marketable Government of Canada bond. ...

It appears that this journal entry may have had some connection to the Invoice; however, the amounts set out in the entry do not correspond with the amounts set out in the Invoice. ...

I do not find that high degree of negligence in connection with the misstatements of business income. ...

It reads: “commercial activity” of a person means (a) a business carried on by the person (other than a business carried on without a reasonable expectation of profit by an individual, a personal trust or a partnership, all of the members of which are individuals), except to the extent to which the business involves the making of exempt supplies by the person, (b) an adventure or concern of the person in the nature of trade (other than an adventure or concern engaged in without a reasonable expectation of profit by an individual, a personal trust or a partnership, all of the members of which are individuals), except to the extent to which the adventure or concern involves the making of exempt supplies by the person, and (c) the making of a supply (other than an exempt supply) by the person of real property of the person, including anything done by the person in the course of or in connection with the making of the supply; [29]         An exempt supply is defined in section 123 of the ETA as a supply which is included in Part VII of Schedule V which in turn states that it is a supply of a financial service that is not included in Part IX of Schedule VI. [30]         Section 123(1) defines a financial service. ...

I do not find that high degree of negligence in connection with the misstatements of business income. ...

In respect of that Statement of Arrears, and in connection with the proposal under the Bankruptcy and Insolvency Act, the respondent demanded payment by Salisbury House of arrears accumulated between March 1, 2006 and April 18, 2006 being the time when either the previous Board of Salisbury House held office or during a time when no Board of Directors held office, or during a time when the previous Board of Salisbury House had abandoned or ignored its responsibilities, such amount totaling $92,826.51 and comprising:     GST Collected   GST ITC Net March 1 to 31: ($87,552.73) + $25,609.39 $61,943.34 April 1 to 18 ($52,454.73) + $21,571.56 TOTAL $30,883.17 $92,826.51             14.       ...

“personal or living expenses” includes (a) the expenses of properties maintained by any person for the use or benefit of the taxpayer or any person connected with the taxpayer by blood relationship, marriage or common‑law partnership or adoption, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit, [34]         Subsection 248(1) of the Act gives a very broad definition of “business”. ...

In addition, the fact that a person segregates from its own funds any monies received or paid in connection with another person is indicative of an agency relationship. … … Remuneration Remuneration of an agent generally takes the form of a set fee. ...

When asked in cross-examination if one of the reasons he gave the Amount to Global was because of a connection to pranic healing, he said he was unable to recall if it was involved in that and did not know whether or not in 2001 Global’s primary purpose was to carry on support programs in British Columbia. [60]   R esponding to questions put to him as to whether he knew how the Amount would be invested by Global, he said he understood it was to be placed into an endowment fund, it would generate interest but did not know where or how the endowment fund was going to earn income and acknowledged he had never donated a nything to an endowment fund. ...