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The Intervener filed the letter with the CRA's Appeals Division for consideration, since it obviously did not agree with Ms.  ...

  [27]     When asked to describe and justify the work during the periods reported on the records of employment, the Appellant's spouse emphasized that it was not only the work performed that should be taken into consideration to justify the remuneration. ...

  [27]     On a consideration of all factors I am of the opinion that the Workers were employees of the Appellant at the material times and not in business on their own account. ...

In the course of the hearing, I brought to his attention subsection 165(1), the main charging provision of the Act dealing with GST: 165(1) Imposition of goods and services tax- Subject to this Part, every recipient of a taxable supply made in Canada shall pay to Her Majesty in right of Canada tax in respect of the supply calculated at the rate of 7% on the value of the consideration for the supply. [27]     Furthermore, under subsection 221(1) of the Act: 221(1) Collection of tax- Every person who makes a taxable supply shall, as agent of Her Majesty in right of Canada, collect the tax under Division II payable by the recipient in respect of the supply. ...

That is, the Respondent's issue estoppel motion requires consideration of a considerable amount of evidence. ...

(b)        The Project Leader guarantees the Foundation that he has read this agreement, is satisfied with and will respect it.   4 CONSIDERATION   (a)        For the services rendered by the Project Leader under this agreement, the Foundation will pay him a fee of $1,346.15 (excluding applicable taxes — GST and QST) every two weeks, for more or less 40 hours/week based on a flexible schedule.   ...

Barring unforeseeable considerations, Mr. Ayotte's lease should begin on July 1, 2003, if the previous Janitor frees his apartment for that date. ...

  [38]     Counsel for the Appellant argues that the Appellant's efforts to find other water suppliers must be taken into consideration and that it cannot be said that the operations ceased on the date of the last invoice. ...

With respect to financial [page442] risk, I respectfully agree with my colleagues that the appellant in consideration for a higher pay gave up many of the benefits which usually accrue to an employee including job security. ...

(e)      Was the promissory note given as part of the consideration        contingent? ...