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As noted in Royal Winnipeg Ballet at para. 64, the relevant factors must be considered “in the light of” the parties’ intent. ... The reply to the notice of appeal states that the Minister assumed that the worker considered himself to be an employee. [23]         Based on the testimony before me, I am satisfied that the worker was aware of the fact that the appellant intended a self-employment arrangement. [24]         The Minister also included in the assumptions that the worker reported what he received from the appellant as “other employment income” on his 2010 income tax return and that the worker did not claim any expenses in his return. ...

The appellant and the Secretariat considered the appellant’s appointment as a member of the Committee to not be insurable. [7]              The Committee members are appointed by the Treasury Board through an Order in Council on the recommendation of the Treasury Board President. ... No. 1643 (QL), [1998] 1 C.T.C. 2453 (T.C.C.). [24]         My learned colleague, Justice Hershfield, considered the same argument in Nuclear Waste Management Organization v. ...

Accordingly, the relationship between the parties must be considered in light of the rules of the Civil Code of Québec, not the tests developed under the common law. ... These slips being common knowledge to Canadian workers, the appellant could easily have required the payer to provide her with copies of the T4slips for tax purposes each year if she had truly intended to work as an employee rather than wait until near the end of her contract with the payer. [37]         The factors to be considered when determining whether or not a person was self-employed are set out in Wiebe Door Services v. ...

There is no dispute between the parties that loans or indebtedness owing by the transferor to a transferee can be considered consideration paid for a transfer for the purposes of subsection 325(1). ... The fact the Appellant’s husband testified he should have contributed but did not, over such a lengthy period of time, without the Appellant having taken any action on the matters suggests the Appellant did not treat these as loans nor considered herself deprived in any way. ...

  [18]         Logically, if “all or nothing offer” offers to settle are not to be considered at all, then it is never open to either a respondent or an appellant in any tax court matter to utilize an offer to settle with costs consequences where there is an all or nothing determination of liability.  ... If “all or nothing” offers can never be considered then the cost provisions related to offers of settlement are inapplicable in such circumstances even though there is no express preclusion in the General Rules. [19]         In order to ascribe some sense to the broad wording of Rules 147(3)(d) and 147(3.1), the issue is not whether an “all or nothing” settlement can or cannot be made with cost consequences.  ...

Issue estoppel has been considered in a number of cases and the principle which can be taken therefrom is that no representation involving an interpretation of law by a servant or officer of the Crown can bind it. ... Inland Industries Ltd., [(1971), 72 D.T.C. 6013 (S.C.C.), at 6017] the Supreme Court of Canada considered certain sections of the Income Tax Act respecting the deductibility of past service contributions to a pension plan initially accepted by the Department of National Revenue for registration but with respect of which deductions were later refused. ...

  [12]         The respondent further argues that it was “entirely reasonable” to test the evidence regarding the truck at trial since the respondent considered that Mr.  ... I do find, however, that the dispute resolution process was undermined through considered inaction. ...

Dupont’s version must also be considered. During the periods at issue, he worked mainly for the Société d’exploitation des ressources de la vallée. ... Savard and Gina Thériault went “very calmly”; he did not complain about the way it was conducted. [28] Furthermore, the appellant acknowledged that the version of her work for the payer attributed to her by Serge Picard, the investigator from the Department of Human Resources Development, differed from the version given at the hearing. [29] All things considered, I prefer Mr. ...

  [15]         The Province of British Columbia considered the Appellant to have been resident in British Columbia in 2008 for the purposes of its Medical Services Plan. ...   [29]         The question of the meaning of “principal place of residence” in paragraph 6(6)(a) has previously been considered by this Court. ...

  [4]              Additional materials (although not necessarily relevant nor properly produced at the Hearing by the Appellants) were, with the consent of the Respondent, received and considered by the Court subsequent to the Hearing. ...   [18]         In deciding this procedural matter, the Court considered the arguments of the parties and indicated its strong inclination that the request for the amendment to insert the section 8 Charter violation arose primarily due to the negligence of the Appellants’ agent in preparing his Notice of Appeal. ...