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The Queen, 94 DTC 6624) to justify her opinion that the co-appellants' business was not a business, but she left out the very part of that same decision which fits this case to a glove, when the learned Judges held that the following criteria should be given consideration in making a determination: the time required to make an activity of this nature profitable, the presence of the necessary ingredients for profits ultimately to be earned. ...

On the basis of that evidence there was a contract of service. [15] Taking into consideration all of the circumstances, including the testimony, admissions and the documentary evidence, I am satisfied that the Appellant has failed in its onus of establishing that the Minister erred in arriving at the conclusion that there was a contract of service. [16] The Workers were engaged by the Appellant in insurable and pensionable employment within the meaning of paragraph 5(1)(a) of the Employment Insurance Act. [17] The appeals are dismissed and the assessments are confirmed. ...

I should think that similar considerations would apply to a violation of a person's rights under the Privacy Act. ...

The contract of sale was filed as Exhibit I-1. [7] On July 9, 1987, Léo Larouche Construction Inc. sold 38 Beauvallon to René Larouche and Johanne Boyer for a consideration of $20,000. ...

The method the employer adopted for obtaining from its clients these amounts which it must pay to its employees (percentage included in computing an aggregate price or added to a base price) and the fact that their amount remains to be determined are immaterial; what is important is that they are amounts payable and promised by the employer in consideration of the employee's work. [13] The two regulatory provisions cited above refer to amounts paid to the employee by the employer in the context of the employment. [14] In the instant case, the payer apparently established a system to enable the employees to share the tips received in the context of their work. ...

The Appellant did not report Lawrence's income in her income tax returns for the three years in issue. [11]          The Appellant had the onus of establishing on a balance of probabilities that the Minister's reassessment for the three years was ill-founded in fact and in law. [12]          I find that the claim that they were living separate and apart during these years is not consistent with the other evidence before the Court. [13]          Taking into consideration all the circumstances of this appeal, including the testimony of the witnesses, the admissions and the documentary evidence in the light of the applicable sections of the Income Tax Act and the well-established case law, I am satisfied that the Appellant has not succeeded in her onus. ...

Gingras. [11] The weight of the evidence shows that the respondent did not judiciously exercise his discretion which requires that he analyse all of the facts that should have been taken into consideration in determining whether or not the employment was insurable. [12] In the light of the evidence, primarily consisting of the testimony of the Gingras brothers since the respondent decided not to call any witnesses, it appears that Gilles Gingras did not profit or benefit from any advantages or disadvantages in performing the work that he did for Les Bras de Fer Gingras Inc. [13] The appellant performed work; he received suitable and reasonable wages reflecting the value of the work performed, which was so performed under the supervisory power of the payer company. [14] The work performed by the appellant during the period at issue, having regard to the special terms and conditions and all the circumstances of its performance, was done pursuant to a genuine contract of service comparable or similar to that which a person dealing at arm's length with the payer would have had. [15] For these reasons, the appeals are allowed in that the work performed by the appellant Gilles Gingras for Les Bras de Fer Gingras Inc., the other appellant, between March 30 and September 25, 1998, was done under a genuine contract of service giving rise to insurable employment within the meaning of the Act. ...

However, she was entitled to a salary in consideration of the services she provided to the accounting business. [6]            What happened here is that Mrs. ...

It was not a travel agency because he found the governmental regulations too onerous, including a surety bond requirement of $35,000. [7] The entire period from the inception of the business in 1991 to the end of 1996 must be taken into consideration and not just the years 1995 and 1996. ...

It reads: 20.01 (1) Notwithstanding paragraphs 18(1)(a) and (h) and subject to subsection (2), there may be deducted in computing an individual’s income for a taxation year from a business carried on by the individual and in which the individual is actively engaged on a regular and continuous basis, directly or as a member of a partnership, an amount payable by the individual or partnership in respect of the year as a premium, contribution or other consideration under a private health services plan in respect of the individual, the individual’s spouse or common-law partner or any person who is a member of the individual’s household if (a)    in the year or in the preceding taxation year (i)      the total of all amounts each of which is the individual’s income from such a business for a fiscal period that ends in the year exceeds 50% of the individual’s income for the year, … [7]              In 2011, the Appellant’s business income was his profit from his insurance business or $558. ...