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TCC

Suco : Solidarité Union Coopération v. M.N.R., docket 2000-2230-EI

Pomerleau were paid in respect of insurable employment during the period at issue, even where those allowances were not paid in consideration of the work performed. ...
TCC

Ibrahim v. The Queen, docket 2000-2555-IT-I (Informal Procedure)

He claims to have written 60 books and having five under consideration with publishers. ...
TCC

Dixon v. The Queen, docket 97-1019-IT-I (Informal Procedure)

The difference cannot be stated in precise and definite terms, but each case must be determined after all of the relevant factors are taken into consideration, but the foregoing indicates in a general way the essential difference. ...
TCC

Caron v. The Queen, docket 98-864(IT)I (Informal Procedure)

Nevertheless, I do not believe that the appellants' project should be disqualified as a result, given the explanations provided-keeping in mind that profitability must be a consideration; that in the opposite circumstances, the arguments made are no longer admissible. [18]     Concerning the appellants' personal expenses, these expenses cannot be charged in part to the building that benefited from them, as was argued by Mr. ...
TCC

Kroeker v. The Queen, docket 97-3126-IT-G

Donnelly [1998] 1 C.T.C. 23: 12 Any doubt as to whether the taxpayer's chief source of income is farming is resolved once consideration is given to the element of profitability. ...
TCC

Hedges-McKinnon v. The Queen, docket 98-1987-IT-I (Informal Procedure)

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. ...
TCC

Calabogie Peaks (1983) Inc. v. M.N.R., docket 98-124-UI

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. ...
TCC

Simmonds v. The Queen, docket 98-9378-IT-I (Informal Procedure)

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

Larouche v. The Queen, docket 98-2395-IT-I (Informal Procedure)

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. ...
TCC

Guimond v. M.N.R., docket 1999-284-EI

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. ...

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