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In case this matter be further considered, and for the moment disregarding all other grounds of defence which have been raised, it may be desirable that I express my opinion upon the question as to whether or not the goods in question, or a substantial portion of them, were in fact exported to the United States. ...

In addition, even if these loans existed, they were not contemplated at the time of transfer of the interest in the Property, and thus, they cannot be considered as part of the consideration given by Ms. ...

This Court considered pa r agraph 8(1)(f) and wrote: [7] P aragrap h (1)(f) …refers to amounts expended. ...

In arriving at the answer to that question, I have considered the assumptions and the evidence under each criterion in turn. 1. ...

Doherty considered various offshore markets that SLAC might consider entering, and provided his recommendations to Mr. ... Furbert also signed an authorization for personal information also dated December 18, 2006, a date before she was even considered for the position and while the offer was pending to Ms. ...

The umpire had held that s. 68 of the Act was the one defining the amount of the premiums the employer had to pay, while the Federal Court of Appeal considered that the applicable provision was s. 66 of the Act. ... Indeed, the majority judges did not have to draw this second conclusion if they considered that Canadian Pacific's obligation resulted simply from the performance of insurable employment. [41]       However, even if I was of the view that the obligation to pay premiums arises under section 51 when insurable employment is performed, without more, subsection (3) thereof provides in effect that in this instance the appellant's obligation could not have arisen during its 1992 taxation year. ...

They cannot succeed in that purpose unless they are considered to be mandatory requirements and strictly enforced. ... The Queen, 2015 TCC 182, [2016] GSTC 53, Associate Chief Justice Lamarre stated as follows: [28] As stated above, when there is an issue of gross negligence, the taxpayer’s conduct should be considered, especially if it must be determined whether the taxpayer was wilfully blind. ...

Likewise, there was no evidence to support the allegations in paragraphs 6(k), (l), (m) or (n), nor the conclusion reached in paragraph 6(o), even if the conditions referred to therein should be a factor to be considered in the contract of service argument. ... Some of the presumptions may have been rebutted and some may even have been supportive of the Appellants’ position but the ultimate result is that the significant allegations detrimental to the Appellants’ positions have not been rebutted and indeed could not have been rebutted without the evidence of the “Payor”. [413] Taken in isolation, the payment of wages in cash may not be significant, but when considered in light of the allegations of the Respondent in the Reply and in light of the failure of the Appellants to produce any corroborative evidence of payment, that fact is of significance. ...

She considered herself to be the bookkeeper and the secretary and MacNeil was managing the office and doing estimates. ... " This, however, is evidence that the term "directors" was considered by MacNeil and he made it clear throughout that the Appellant was a party to mostly all of these meetings if not all of them and the same information was made available to the Appellant from their lawyers, accountants and auditors as was made available to MacNeil. ...

If the pre-union Newfoundland statutes are to be considered as continuing in force after the proclamation of the Dominion statutes, on the theory that the Newfoundland acts are special legislation and, therefore, constitute an exemption from the terms of the general Acts, s. 49 of the 1949 Act, already quoted, is effective to abolish the position obtaining under the special legislation. ... The respective jurisdictions of the Dominion and the Province in respect to pre-Confederation legislation was considered by the Privy Council in A. ...