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Therefore, in this case, the Coal Company, for the purposes of all taxation, must be considered as the actual owners of the part of the wharves occupied by it for its coal business and as a consequence the coal towers installed and working on that space of ground, as well as the power house erected thereon, must be considered as incorporated thereto, and are immovable property as long as they remain there, according to the article of the code above mentioned. ...

By judgment, rendered concurrently with that on the main action, the learned trial Judge considered that it necessarily followed from the dismissal of the main action that the action in warranty was left without basis and could not accordingly be maintained, and it was dismissed with costs. ... As for the action in warranty, it was considered as being nothing else but the exercise of an action in indemnity, subordinate to the fate of the principal action, and, as the plaintiff in warranty was not condemned, the principal action having been dismissed, the warranty action was held to be without legal basis, and it was dismissed with costs. ...

In the present case the Company is an ordinary commercial corporation and cannot, by any possible view of its status, be considered to come under one or the other of these designations. ... If these contracts, instead of being with a Company had been made with an individual, it seem that they would clearly have been considered as contracts of agency or service, and the fact that we have here a Company instead of an individual makes no difference (C.C. 1701; Quebec Asbestos Corp. v. ...

And it is agreed in consideration of the premises that all goods, chattels, household furniture, moveables and effects at any time found in and garnishing the common domicile of the parties hereto, whatever may or shall be the value thereof, and however acquired, shall be held and considered as belonging to the said party of the second part exclusively, the said party of the first part hereby abandoning in her favor, she accepting thereof all right, title, interest and claim he may have thereto or therein. ... Fleet to pay his widow the sum of $20,000 can be considered a debt, it is not such a debt as was created for full consideration in money or money’s worth wholly for the deceased’s own benefit. ...

The Minister affirmed the assessment, stating his decision as follows: ‘“The Honourable the Minister of National Revenue, having duly considered the facts as set forth in the Notice of Appeal and matters thereto relating, hereby affirms the said Assessment on the ground that the taxpayer is not entitled to an allowance under the provisions of sub-section (a) of section 9 of the Income War Tax Act for the exhaustion of timber limits owned by the Crown in right of the Province of Alberta on which the taxpayer has been licensed to cut timber. ... So far their Lordships have considered the language of the Statute as it at present stands. ...

The rest of section 3 in Part I of Schedule V does not apply, given the surrounding circumstances of this appeal. [6] The relevant parts of the definition of “builder” [5] are as follows: 123. (1) “builder” of a residential complex … means a person who (a) at a time when the person has an interest in the real property on which the complex is situated, carries on or engages another person to carry on for the person (iii) … the construction or substantial renovation of the complex, … but does not include (f) an individual described in paragraph (a) … who (ii) engages another person to carry on the construction or substantial renovation for the individual… otherwise than in the course of a business or an adventure or concern in the nature of trade… [7] In other words, the construction or substantial renovation must be done in the course of a business or an adventure/concern in the nature of trade in order for the person to be considered a “builder”. ... I accept that he and his wife considered their ability to qualify for the latter in deciding which path to take (i.e. sell or not). [27] The appellant had no experience building a house and additionally, no experience balancing the co-existing possibilities of living in the house or selling it for a profit. ...

The CRA treated these submissions as a request for a second review of his eligibility for the CERB and the CRB. [8] As part of their review, the Officer considered various documents and information, including prior entries made by other CRA officers on its computer systems, the Applicant’s prior submissions, information gathered during telephone calls with the Applicant, and the Applicant’s income and deductions from income for the 2019, 2020, and 2021 taxation years. [9] While the Applicant had earned over $5,000 of gross self-employment income in the 2019 and 2020 taxation years, he suffered net losses. ... I have therefore not considered the Applicant’s arguments as they relate to the CERB decision. ...

The letter also specifically states that “If you are not a GST/HST registrant with a business activity involving real property transactions, and you are involved in one real property transaction, you have to report the tax you are considered to have collected on form GST 62, Goods and Services Tax/Harmonized Sales Tax (GST/HST) Return (non-personalized).” [12] Mr. ... Gerlings was deemed, by the CRA, to be a builder of a house and considered to have made a taxable self-supply on the date of transfer to his mother. ...

Rather, it is “an extension of her power to issue an NIR and properly considered together with the NIR appeal.” ... In light of these circumstances, I am of the view that this question should be considered by the panel of this Court assigned to hear the merits of this appeal. ...

Both the outcome of the decision and its reasoning process must be considered in assessing whether these hallmarks are met (Vavilov at paras 15, 95, 136). [21] Such a review must include a rigorous evaluation of administrative decisions. ... Indeed, the appeal was doomed to fail for two reasons: (i) the Appeal Division properly considered and rejected Mr. ...