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The Minister also made the alternative assumption that the Appellant did not incur such expenses and that, if he did incur them, they were personal. [48]         The confusing evidence does not enable me to determine that some versions of the T2200s should be considered authoritative as opposed to others. ...

Even if the Court considers the Appellants’ argument as to the use of the line of credit and accepts that it is plausible, in the absence of corroborating documentation, the question is whether it is credible, all things considered. [35]         I am of the view that Mr.  ...

The Order of the FCA was to leave in the impugned portions of the Appellant’s pleadings to be considered by the trial judge. ...

The Appellant argued that TTIC’s business records, obtained from a third party, should not be considered reliable given the nature of TTIC’s allegedly illegal operations and the serious allegations and charges made against TTIC and Alan Kippax, as set out in the evidence he submitted. ...

Jonathan Flynn’s wife attended to these matters and was paid accordingly. eee)          the Appellant paid Dwayne a Christmas bonus of $1,000 on December 23, 2013; fff)             the Appellant paid the Worker total wages of $32,479.70 in 2013; ggg)         the Appellant paid Dwayne total wages of $35,934.05 in 2013; hhh)       the Appellant did not offer medical or dental benefits to any worker; iii)               the Worker and Dwayne used the Appellant’s service vehicles for personal use; jjj)               the service vehicles were marked with the Appellant’s business logo; kkk)       the Appellant considered the workers’ use of the vehicles as advertising; lll)               during the winter season, the Worker stored the service vehicles at his home, at Don’s home or at the Worker’s parents’ home; Mr.  ...

Justice Bowman, at paragraph 16, sets out a number of criteria that a taxpayer must prove if a project’s activities are to be considered SR&ED: […] 1. ...

The statute been considered to be broad enough as a matter of strict construction to give the Minister this power: see Hoobanoff Logging Ltd. v. ...

[Emphasis added.] [33]         Thus, the definition of “insurable employment” itself provides for the situation where a person is bound by a contract of employment to another person, while a different person pays the remuneration. [34]         In addition, the Insurable Earnings and Collection of Premiums Regulations (SOR/97-33) made under the Act also provide for situations where the person who pays a worker’s remuneration is considered the “deemed employer” and is obliged to collect and remit employment insurance premiums. ...

It is even more improbable that they continued to stay at the Unit for an additional four months after the realization before returning to the Rockford property. [39]         Their testimony that they had not considered selling the Unit before February 2010 is contrary to the testimony by the appellant in cross‑examination that the photos of the Unit were taken on January 9, 2010, for posting in the MLS listing to sell the Unit. ...

As noted in Royal Winnipeg Ballet at para. 64, the relevant factors must be considered “in the light of” the parties’ intent. ...