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Commercial activity is defined as follows in subsection 123(1) of the ETA: "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. [44]            Thus, the REOP test is specifically included in the legislative provision which defines commercial activity. ...

In connection with the Product License Agreement, NNS asked the workers to sign an Independent Contractor Agreement, and in an addendum thereto, V1 Labs Inc., agreed that the worker would remain its employee. ...

In the case at bar, the appellant essentially raised the limitation issue; he did not submit any evidence in connection with the defence of care, diligence and skill ...

Even real evidence, which exists independently of any statement by any witness, cannot be considered by the court unless a witness identifies it and establishes its connection to the events under consideration. ...

I will address these additional questions in connection with the particular demand under which they were formulated and submitted during the hearing of the Motion.   ...

With respect to issue c), the Respondent now maintains that it is no longer feasible to look at all services and property provided by Costco to Amex as a single supply, rather Costco was making two separate supplies: one, a supply of exclusivity rights and two, a supply of marketing, promotional and administrative services in connection with the Co‑Branded cards. ...

 (1) There shall be included in computing the income of a taxpayer for a taxation year as income from an office or employment such of the following amounts as are applicable:   …   (b) all amounts received by the taxpayer in the year as an allowance for personal or living expenses or as an allowance for any other purpose, except   …   (vii) reasonable allowances for travel expenses (other than allowances for the use of a motor vehicle) received by an employee (other than an employee employed in connection with the selling of property or the negotiating of contracts for the employer) from the employer for travelling away from   (A) the municipality where the employer's establishment at which the employee ordinarily worked or to which the employee ordinarily reported was located, and   (B) the metropolitan area, if there is one, where that establishment was located,   in the performance of the duties of the employee's office or employment,   [21]     It seems clear that since the meal allowance of $18 per day paid by the Appellant’s employer was not a reasonable allowance for the days during which the Appellant was required by his duties to be away from Winnipeg for 12 hours or more, the total amount of this allowance would be included in the income of the Appellant. ...

It is also important to note that, during the periods in question, the Appellant did not self‑assess in connection with any of his buildings, and did not pay any GST, on the basis that everything was cancelled out by the ITCs that the Appellant claimed on account of expenses in his financial statements ...

Paragraph 8(1)(f) of the Income Tax Act provides in part as follows:   8. (1) In computing a taxpayer's income for a taxation year from an office or employment, there may be deducted such of the following amounts as are wholly applicable to that source or such part of the following amounts as may reasonably be regarded as applicable thereto:   …   (f) where the taxpayer was employed in the year in connection with the selling of property or negotiating of contracts for the taxpayer's employer, …   amounts expended by the taxpayer in the year for the purpose of earning the income from the employment (not exceeding the commissions or other similar amounts referred to in subparagraph (iii) and received by the taxpayer in the year) to the extent that such amounts were not   (v) outlays, losses or replacements of capital or payments on account of capital, except as described in paragraph (j),…   [8]      A restriction imposed on the deductibility of the amount expended in computing income from employment is that it must have been expended for the purpose of earning income from that employment. ...

The Appellant himself testified, and Yves Ladouceur, the executing notary in connection with, inter alia, the Appellant's acquisition of the various properties and the creation of the $1,500,000 hypothec that the Appellant granted to Samisa, also testified in support of the Appellant's position.     ...