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The right of respondent to be reimbursed these moneys, which it paid to appellant, involves the consideration of two questions: (i) Whether, under the general law, there is, in like circumstances, a right to recover moneys paid, and, in the affirmative, (ii) Whether this right to recover, under the general law, is barred, in the present instance, by any of the statutory provisions of the Excise Tax Act. ...

Gordon Denford corroborated the Appellant's deposition regarding a) their dispute about the extent of the renovation work, b) the giving of guarantee by the Appellant for no consideration on two distinct occasions, and c) the fact that no interest was payable on the monies advanced to Fort Chelsea by the Appellant and himself, except with respect to the portion of the advances made by Mr. ...

The standard to be applied is one of reasonable consideration. But it is clear that the proper approach to applying paragraph 55(1)(c) of the Act requires that one views the transactions as a whole rather than in isolation. ...

He searched the data bank for additional documents on or about September 25, 1996 to find additional documents dealing with facts similar to those in the appellant's appeal where there was a consideration of GAAR. ...

Or, outre le degré de contrôle exercé par l’employeur, les facteurs habituellement pertinents à prendre en considération comprennent les points de savoir si le travailleur « fournit lui-même son outillage, engage ses assistants, gère et assume des risques financiers, et peut escompter un profit de l’exécution de ses tâches » (1392644 Ontario Inc c Canada (Revenu National), 2013 CAF 85, para 41 [Connor Homes], para 41). ...

In addition, there are other cases involving consideration of the decision in which the Income Tax Appeal Board dismissed the taxpayer’s appeal and he brought an appeal from its decision to this Court. ...

With these considerations in mind, I proceed to consider the facts applicable to each of the years under review. ...

The factor of space is rele vant upon a consideration of the equity of the double taxation to which profits so earned may be subjected, but it does not, it is submitted, cast any doubt upon the legality of the practice.” 12 * Compare The Gramophone and Typewriter, Ltd. v. ...

Thomson explained part of this purpose that the appellant should dispose of its members’ surplus horses as advantageously as possible for them but the disposal of them was the main consideration. ...

As described by Justice Noël in Brar, the appeal is “robust.” [63] I acknowledge that |||||||||| ’s Charter and constitutional arguments deserve consideration and note that similar issues have been raised before this Court in other proceedings. ...