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Consequently, Glen Dimplex approached the investors group and agreed that if the group would walk away from the deal (i.e. not make a bid with respect to Chromalox) Glen Dimplex would pay the group $1,000,000. (4)            Glen Dimplex feared that the $1,000,000 payment would attract GST and consequently raised the total to $1,070,000 to take into consideration the seven percent GST tax on the $1,000,000. (5)            There was some discussion as to whether the $70,000 should be considered as interest as opposed to GST but, in my opinion, the evidence leads to the conclusion that the $70,000 represented GST. (6)            Another fact is that the Appellant did not file a GST return in respect of the said transaction as it was the Appellant's conclusion that the transaction was exempt from GST as constituting either a financial service or a foreign transaction. (7)            The last reassessment by the Respondent took place on October 26, 1998 which is approximately six years after the filing due date. [3]            A Notice of Objection was filed with respect to the assessment of October 26, 1998. [4]            Some of the most relevant documents are the agreement between Glen Dimplex and the investors group which was signed in Toronto and a related trust agreement appointing John Ingle and Steven Overgaard as trustees for the investment group also signed in Toronto (Tabs 2 and 3 of the Appellant's Documents) ...

At my invitation during the conference call to make representations in the present matter, counsel for the Appellants did not attempt to distinguish the issue in the present cases from that considered by the Federal Court of Appeal in the Trengrove case mentioned earlier. [6] Judge Rip had decided in the Trengrove case that the new Housing Rebates, on account of FST and GST, which had been transferred to the builders formed part of the consideration that was subject to GST. [7] I am of the opinion that the decision of the Federal Court of Appeal is applicable to the present appeals, the issue being the same in both sets of cases. [8] I therefore come to the conclusion that the FST and GST new Housing Rebates which were assigned/transferred to the Appellants herein formed part of the value of consideration for the supply of the new houses. [9] Accordingly, the appeals from the assessments are dismissed with costs. ...

He later realized his mistake and concluded that he could obtain additional input tax credits if he was considered the contractor for part of the invoices. ...

I have considered the submissions made and the evidence and I cannot find any valid legal reason to conclude that these expenses are somehow deductible in 1992. ...

The waiver of penalty and interest in excess of 4% of the tax not properly charged in a “wash transaction” will normally be considered automatically by the Minister during the audit process. ...

Institute of Technology, the Payor, when he was on unpaid leave should be considered as insurable earnings when they were paid or if they had to be used as "top up" to his last regular pay period within the meaning of the Unemployment Insurance Act. [2] The Respondent informed the Appellant that it had been determined that vacation pay had to be allocated to the last pay period in which he was employed with the Payor. [3] The Appellant was employed with the B.C. ...

McArthur of this Court reduced the expenses claimed to what he considered reasonable amounts and allowed certain losses for the 1989 and 1990 years. ...

") has appealed a decision dated March 20, 1997 that it "is considered to be a deemed employer" under the Unemployment Insurance Act for the calendar years 1995 and 1996 of "drivers" who did not own taxicabs dispatched by the Appellant, but drove the taxicabs. [2] The evidence is that C.C. owns one handicap van and dispatches twelve taxicabs owned by other individuals and corporations in Kelowna, British Columbia and did so in 1995 and 1996. ...

With all respect to the members of the Appellate Division, I agree with the learned trial judge that a valid sale of this motor vehicle had been made to the defendant Peter Pidoborozny (the father) and that he was the owner at common law notwithstanding the fact that his son had made the payments under the conditional sales contract and had had exclusive possession of the vehicle from the date of its purchase. [11] I recognize that these two cases interpreted the word "owner" within the meaning of the provincial legislation and that other things may have to be considered in deciding the meaning of the words "acquire", "supply" or "import". ...

The following criteria should be considered: the profit and loss experience in past years, the taxpayer’s training, the taxpayer’s intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...