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Revenue Canada proposes to settle the present files as follows: Alpha Leather Canada Ltd. 1991 1992 1993 A) Expenses allowed 1) Selling salaries 8,500 10,500 7,041 2) Unrealized foreign exchange loss 122,404 B) Reduction of losses cancelled 417,448 * As discussed, the Notice of Objections for 1990 and 1994 are considered invalid. for the Chief of Appeals Montreal District Office Acceptance: The undersigned, Mr. ...

The Court found that the absence of any provision in its Rules for proceedings in forma pauperis was not the result of any oversight and was more likely to be a conclusion that after due consideration it was not considered necessary. ...

The scope and purpose of section 15 of the Act has been considered many times, most notably in Minister of National Revenue v. ...

Similarly, if the Tribunal considered all the mandatory kinds of evidence but still reached the wrong conclusion, then its error was one of mixed law and fact. ...

These words are explained in paragraph 2900(2)(b) of the Regulations, which reads as follows: (2) For the purposes of clause 37(8)(a)(i)(B) and subclause 37(8)(a)(ii)(A)(II) of the Act, the following expenditures are directly attributable to the prosecution of scientific research and experimental development: (b) where an employee directly undertakes, supervises or supports such prosecution, the portion of the amount incurred for salary or wages of the employee that can reasonably be considered to be in respect of such prosecution; and It is also helpful to read subsection 37(9) of the Act, which provides that an expenditure of a taxpayer does not include remuneration based on profits or a bonus where the remuneration or bonus is in respect of a specified shareholder who is also an employee. ...

Then the appellant said he would pay the tax and interest, but he considered the penalties “a bit harsh”. ...

His evidence was clear that these factors were considered when Revenue Canada was devising the proper formula for the assessment of tips. ...

H.M. [3] this Court considered earlier jurisprudence and confirmed the basic principle that it is the duty of the Minister to assess, and if necessary reassess, taxpayers’ returns so as to apply correctly the law to the facts. ...

Pauzé considered the reimbursement of his expenses to be a form of pay is a very revealing indication that he may have been mistaken as to the tax treatment of the money paid to him by Référium. ...

Generally a loan made by a person who is not in the business of lending money will be considered to be an investment. ...