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Those not signing similar contracts were Walter Cebuliak ("Cebuliak"), William Heward ("Heward"), Damon Reiger ("Reiger") and Ronald Kambeitz ("Kambeitz"). [5] Scheiris testified that when the Appellant received a project from a client it would offer some or all of the workers the opportunities to work on a particular job, execute a written quote, execute a "Independent Contractor Agreement" specifying the services to be provided in connection with that job, the commencement date of same, the deadline for its completion, the fee to be paid to that worker by the Appellant and the penalty to be paid for late performance. [6] Scheiris said that flat fees were negotiated between the Appellant and the workers for their services. ...

In particular, the Appellant referred to a Remission Order which might apply to members of the band that he claims to be a member of with respect to income earned on the reserve in the period from 1972 to 1984, 1985 and 1986. [6] I questioned the Appellant as to whether he was in the right Court; whether he should be looking for a declaration, perhaps from the Federal Court, Trial Division, concerning his status as a member of a particular Aboriginal band; and whether in connection with such declaration he might also consolidate a declaration as to whether he falls within a Remission Order that apparently was issued by the Minister of National Revenue with respect to members of the band. [7] The Appellant informed me that he already had one proceeding in the Federal Court, Trial Division, in which he has retained counsel. ...

Paragraph (a) of that definition reads: (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 adoption, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit. [19] Here, I think the expenses, at least with respect to the upper half of the house where the appellant's mother lived at a reduced rent, fit precisely into that definition. ...

Justice Dickson said at page 5045: The phrase "in respect of" is probably the widest of any expression intended to convey some connection between two related subject matters. ...

The making of a supply of real property, including anything done by the person in the course of or in connection with the making of the supply. [10]          "Property" means any property, whether real or personal, movable or immovable, tangible or intangible, corporeal or incorporeal, and includes a right or interest of any kind, a share and a chose in action, but does not include money. ...

Apparently, Brockelbank was a substantial operation with its own tractors and trailers, a dispatcher, and commercial connections throughout Canada and the United States. ...

Taxable supply means a supply that is made in the course of a commercial activity, according to the definition of this expression in subsection 123(1) of the Act. [15]         The expression “commercial activity” is also defined in subsection 123(1) of the Act, which states the following: “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; [16]         By that definition, the making of exempt supplies is excluded from commercial activity. [17]         Subsection 9(2) of Part I of Schedule V sets out that the sale of real property by an individual is an exempt supply, except in the circumstances listed in subsections 9(2)(a) to (f). [18]         One of the exceptions, at subparagraph 9(2)(b)(ii) of Part I of Schedule V of the Act, sets out that the supply of real property made in the course of an adventure or concern in the nature of trade is not an exempt supply if the individual filed an election with the Minister containing prescribed information. ...

Feil’s corporation was a member of Feil & Co. and that Feil & Co. would have been aware through this connection that the Corporation Sole was just a conduit. [28]         I would conclude that the respondent was correct to conclude that the cheques written by Feil & Co. were in fact payments to Mr. ...

The Deputy Attorney General relies on the following additional facts: a)         in April 2014, as a result of an investigation of the XXX Tax Shelter by the Royal Canadian Mounted Police ("RCMP"), principals and representatives of XXX and ABC ( … ) were charged with the following offences in relation to their activities in connection with the XXX Tax Shelter: •          fraud over $5,000.00 contrary to paragraph 380(1)(a) of the Ciminal Code; •          conspiracy to commit fraud over $5,000.00 contrary to paragraph 465(1)(c) of the Criminal Code; •          laundering proceeds of crime contrary to subsection 462.31(1) of the Ciminal Code; and •          commission of an offence for the benefit for a criminal organization contrary to section 467.12 of the Criminal Code. [3]              The charges listed in Bullets 2 and 3 were not in fact laid against the individuals and representatives of XXX. [4]              I granted the appellant's motion to strike paragraph 76 from the respondent's pleadings on the basis the paragraph's contents were scandalous and an abuse of the process of the Court: Rules 53(1)(b) and (c), as well as potentially prejudicing or delaying the fair hearing of the trial: Rule 53(1)(a) of the Rules. [5]              In short, the persons referred to in paragraph 76 of the reply were charged with offences under the Criminal Code but not convicted of any charges. ...

The Appeal [9]              Paragraph 8(1)(c) of the Income Tax Act (“ ITA ”) reads:   (1) Deductions allowed-- 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:   (c) clergy residence-- where, in the year, the taxpayer   (i) is a member of the clergy or of a religious order or a regular minister of a religious denomination, and   (ii) is   (A) in charge of a diocese, parish or congregation,   (B) ministering to a diocese, parish or congregation, or   (C) engaged exclusively in full-time administrative service by appointment of a religious order or religious denomination,   the amount, not exceeding the taxpayer 's remuneration for the year from the office or employment, equal to   (iii) the total of all amounts including amounts in respect of utilities, included in computing the taxpayer 's income for the year under section 6 in respect of the residence or other living accommodation occupied by the taxpayer in the course of, or because of, the taxpayer 's office or employment as such a member or minister so in charge of or ministering to a diocese, parish or congregation, or so engaged in such administrative service, or   (iv) rent and utilities paid by the taxpayer for the taxpayer 's principal place of residence (or other principal living accommodation), ordinarily occupied during the year by the taxpayer, or the fair rental value of such a residence (or other living accommodation), including utilities, owned by the taxpayer or the taxpayer 's spouse or common-law partner, not exceeding the lesser of   (A) the greater of   (I) $1,000 multiplied by the number of months (to a maximum of ten) in the year, during which the taxpayer is a person described in subparagraphs (i) and (ii), and   (II) one-third of the taxpayer 's remuneration for the year from the office or employment, and   (B) the amount, if any, by which   (I) the rent paid or the fair rental value of the residence or living accommodation, including utilities   exceeds   (II) the total of all amounts each of which is an amount deducted, in connection with the same accommodation or residence, in computing an individual 's income for the year from an office or employment or from a business (other than an amount deducted under this paragraph by the taxpayer), to the extent that the amount can reasonably be considered to relate to the period, or a portion of the period, in respect of which an amount is claimed by the taxpayer under this paragraph; [10]         At the hearing, the Appellant stated that he satisfied the conditions given in paragraph 8 (1)(c) of the ITA. ...