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The shareholdings then became: Mr Warmington 224 shares Mr Affettuso 96 shares Mrs Warmington 80 shares Mr Warmington then considered it expedient to sell shares to two other employees, so the shareholding then became: Mr Warmington 157 shares Mr Affettuso 96 shares Mrs Warmington 80 shares Ron Errett 40 shares Hans Gruhn 27 shares This persisted for three years when Messrs Errett and Gruhn expressed the desire for a greater shareholding interest to the extent that Mr Warmington would lose his individual control. ... The contention on behalf of the Minister, put conversely, is that a group of persons may be considered to control a corporation even though one member of the group may own sufficient shares to control the corporation. ... A “group of persons” may be considered to control a corporation even though one member of the group may own sufficient voting shares to be in a position to control it. ...

Counsel for the Minister indicated that she would be prepared to treat the notice of motion as having been properly amended to request such a remedy, and counsel for the applicant agreed that this could be considered as an alternative remedy sought by him. ... Carbone found four documents which he considered relevant to Mr. Tyler's tax position and made copies of these. ... Tyler simply states that he is unwilling to furnish any financial information which may be used as evidence against him in the criminal proceedings and states that his counsel has advised him that "evidence" obtained through the tax audit would be considered relevant at his trial. ...

Accordingly, when considered in this context, the use of the sole word "expenditures" in the clause (A) definition section means that both current and capital expenditures are included. ... Having determined that the expenditures may be apportioned, at least to some extent, between SR&ED and other uses, it must now be considered whether the 47.3 per cent portion of current expenditures claimed by Imapro in 1988 for expenses pertaining to the maintenance and upkeep of common areas of the building are substantially all attributable or directly attributable to the prosecution or provision of premises, facilities or equipment for SR&ED. ... These facts, when considered in their totality, establish that the common and administrative areas of the building are integral to the functioning of the research and development sector and are used routinely and regularly by its employees. ...

For example, issues pertaining to freedom of religion, freedom of expression and the right to life, liberty and the security of the individual will have to be considered by the courts. Decisions on these issues must be carefully considered as they will profoundly affect the lives of Canadians and all residents of Canada. ... To attempt to do so would trivialize the Charter and inevitably result in ill- considered opinions. ...

Counsel for the Minister has characterized it as disclosing to the taxing authorities those things which the plaintiff believed would be discovered in any event and withholding information which the plaintiff considered could not be discovered by Keirstead. ... I can appreciate that there would be some difficulty in her doing this with any great degree of accuracy but I am sure she considered at the time that a difficulty for her would be an impossibility for a stranger and deliberately elected not to assist in the preparation of the statement of her personal expenses so that Keirstead would either be frustrated in his attempt to do so or, alternatively, that any statement prepared without her assistance would be so inaccurate that it could be successfully attacked as being meaningless. ... P-2): Increase in Net Worth Income Previously Reported Unreported Income 1976 $15 852 $14 530 $ 1 322 1977 $30 806 $19 263 $11 543 1978 $16 044 $16 708-$ 664 1979 $46 865 $19 283 $27 582 Assuming there was no partnership between the plaintiff and her husband, and making other adjustments which the plaintiff's expert considered warranted, the plaintiff's expert, at the end of the trial, calculated the changes in the plaintiff's actual and reported income as follows: Increase in Net Worth Income Previously Reported Unreported Income 1976-$22 837 $14 530 — $37 367 1977 $43 301 $19 263 $24 038 1978 $12 892 $16 708-$ 3 816 1979 $70 641 $19 283 $51 358 In my view Ex. ...

Among possible interpretations, only those toilet articles or cosmetics that are intended for use for toilet purposes are to be considered "cosmetics". If they are intended to be used for other purposes, they are not to be so considered. ... Glass, despite the objections of counsel for the plaintiff, I do not find it persuasive and therefore give it no weight. [34]      Counsel for the Crown argued that not all toilet articles can be considered cosmetics because it stretches the meaning of "cosmetic" too far. ...

Therefore, this matter will not be considered. ANALYSIS Jurisdiction [26]            As indicated by the Federal Court of Appeal in  Canada (M.N.R.) v. ... Desgagnés, family relations, Roger Blouin’s affidavits and cross-examination) appears to indicate that Roger Blouin considered himself insolvent and sought to prefer his mother and aunts. ... The seizing creditor also admits that there is no precedent in which knowledge of the personal circumstances of the authorized representative was assimilated to the person issuing the mandate based on information the latter obtained within the framework of the mandate. [60]            These distinctions are important, and the Court is not convinced that the principles of  Wilks, above, are applicable to this case. [61]            Whatever the case, the parties agree that even if the opposing parties are legally incapacitated, they still retain the ability to receive payments, if this action can be considered as a juridical fact. ...

  [9]         First, at pages 729 to 833 of First Vancouver, the Supreme Court made a connection between the vehicle of the deemed trust granted to the Minister by the ITA and the importance of collecting source deductions; at the same time, in order to justify the absolute priority enjoyed by this deemed trust, the Supreme Court stressed the opportunity that these financial institutions have to become familiar with the tax debtor ’ s business and finances and also considered the major amendments now reflected in subsection 227(4.1) of the Act, in response to Royal Bank v. ...   [13]       More often, compensation is primarily considered a form of security interest.  ...   [24]       In my opinion, these facts, considered together with clause 7 of the contract to secure savings, show that the defendant decided not to exercise its right to effect compensation prior to February 21, 2001, as noted on the deposit agreement, that is, when it stopped allowing the interest stipulated therein to accrue ...

The definition found in the Shorter Oxford English Dictionary on Historical Principles is illustrative of what is found in other dictionaries: Vehicle: A means of conveyance provided with wheels or runners and used for the carriage of persons or goods. [29]            The same idea transpires from the various decisions that have considered the proper construction to be given to this word. ... Since they will never again function as air conditioners in those vehicles as imported by the Plaintiff, they cannot be considered as "equipment" for those vehicles. ... Accordingly, at this point in time, the air conditioner cannot be considered a permanently installed equipment anymore, considering the change in nature of the object into which it is found and in light of the intention of the importer. [41]            I realize that this whole discussion around the true nature of a vehicle may look like an theoretical exercise that is far removed from the practicalities to be addressed by the Excise Tax Act. ...

Dès lors, il avise le contribuable de sa décision par écrit. 169. (1) Where a taxpayer has served notice of objection to an assessment under section 165, the taxpayer may appeal to the Tax Court of Canada to have the assessment vacated or varied after either 169. (1) Lorsqu'un contribuable a signifié un avis d'opposition à une cotisation, prévu à l'article 165, il peut interjeter appel auprès de la Cour canadienne de l'impôt pour faire annuler ou modifier la cotisation: (a) the Minister has confirmed the assessment or reassessed, or a) après que le ministre a ratifié la cotisation ou procédé à une nouvelle cotisation; (b) 90 days have elapsed after service of the notice of objection and the Minister has not notified the taxpayer that the Minister has vacated or confirmed the assessment or reassessed, b) après l'expiration des 90 jours qui suivent la signification de l'avis d'opposition sans que le ministre ait notifié au contribuable le fait qu'il a annulé ou ratifié le cotisation ou procédé à une nouvelle cotisation; but no appeal under this section may be instituted after the expiration of 90 days from the day notice has been mailed to the taxpayer under section 165 that the Minister has confirmed the assessment or reassessed. toutefois, nul appel prévu au présent article ne peut être interjeté après l'expiration des 90 jours qui suivent la date où avis a été expédié par la poste au contribuable, en vertu de l'article 165, portant que le ministre a ratifié la cotisation ou procédé à une nouvelle cotisation. [17]       These two provisions were considered by the Federal Court of Appeal in its decision of December 21, 2000 in James v. ... The taxpayer may appeal to the Tax Court under paragraph 169(1)(b), or commence proceedings in the Federal Court to compel the Minister to consider the objection and deal with it.... [20]       Moreover, allowing assessments to be vacated on the ground that the Minister failed to confirm an assessment with due dispatch would frustrate Parliament's intent by rendering meaningless paragraph 169(1)(b) of the Act, which expressly gives taxpayers a remedy when the Minister fails to confirm an assessment within a period considered appropriate by the taxpayer. ... Webster discovered that the Minister's official who had considered his objections might have had access to information that he had been denied. [30]       At paragraph 10 of its reasons, the Court summarized Mr. ...