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It therefore appears from the evidence that, even in the best conditions, income could not have covered expenses. [17]          Thus, maximum production sold at a price considered very good was not sufficient to meet overhead, as a result of which there clearly could be no reasonable expectation of profit. [18]          Furthermore, the revenue and expenditure figures hereunder for 1991 to 1997 speak for themselves: [TRANSLATION]                 Evaluation- Reasonable Expectation of Profit                 The gross revenue and farm losses reported by the appellant from the sugar bush operation were as follows during the 1991 to 1997 taxation years:                                 Year                                         Revenue                                 Expenditure                 (i)               1991                                            $ 900                                 $ 15,000                 (ii)              1992                                           $ 3,518                                 $ 15,000                 (iii)             1993                                           $ 1,250                                 $ 12,506                 (iv)             1994                                           $ 1,200                                 $ 17,738                 (v)              1995                                            $    600                                 $ 17,950                 (vi)             1996                                           $ 2,560                                 $ 11,809                 (vii)            1997                                           $ 3,500                                 $ 11,486                                                                                  $13,528                                 $ 101,489 [19]          During the period of 1995, 1996, 1997 and 1998, the main purpose of the business was to produce maple syrup and sell by-products or processed products made from maple sap, the raw material that was obtained. ... In my opinion, because of the new case law by which this Court is bound, the losses in the years in issue must be considered as restricted losses. [28]          To determine whether a taxpayer has put the main elements in place to achieve future profitability in any business, it is important to consider the matter at the time it occurred. ...

These companies, in turn, were contracting out services with offshore construction companies or oil companies; h)             the payments for those contracts came from the offshore construction companies or oil companies to the survey companies to the foreign recruitment company DOOR to finally reach the Canadian company HMSI; i)               during the 1997 taxation year, the invoicing was always done between HMSI and the Dutch recruitment company DOOR and no invoicing was done by the Appellant himself; j)               the Appellant did not receive a regular salary from HMSI and was dependent upon foreign payments made to HMSI to collect any money; k)              the Appellant supervised the team who did the hydrographic survey and both the team and the Appellant, through HMSI, were hired by DOOR; l)               the Appellant did not have a written contract with his own company HMSI and HMSI did not have any written contract with DOOR; m)             if HMSI is deemed to be the Appellant's employer, it is not a specified employer since the nature of its activities was throughout the 1997 taxation year, the onshore/offshore personnel recruitment and HMSI did not carry on business in the country in which the Appellant performed his duties; n)             HMSI carries on a business of providing services and does not employ in the business throughout the year more than 5 full-time employees; o)             HMSI and even DOOR did not have any contracts with the companies who were performing qualifying activities during the 1997 taxation year; p)             but for the existence of HMSI, the Appellant would reasonably be regarded as an employee of DOOR that is a non-resident company, carrying business of providing services as a recruitment company and was therefore not a specified employer; q)             moreover, the Appellant entered in an employee/employer relationship with DOOR customer, the survey company which was also a foreign company and therefore could not be considered a specified employer. This relationship was based on the following facts: i)               the Appellant was working under the supervision of DOOR customer and was reporting to that customer every day to give him a full report of the day activities; ii)              the Appellant's remuneration was based on a daily rate for the duration of the contract, independently if he was working or not; iii)             the Appellant was using the equipment and the material of the survey company; iv)            the Appellant was living aboard the ship which belongs to the oil company, for the duration of the contract without paying anything for his room and board; v)             the Appellant was reimbursed for his transportation to the ship; vi)            the Appellant did not work within a budget and there was no specific date to end the contract; vii)           when the Appellant was hired, he only knew approximately how long will be the contract and the task to be done might change accordingly to the client's needs (the survey company) and his employment might cease at any time without any notice and he could be replaced by somebody else for whatever reason; viii)          the Appellant was working exclusively for the survey company and could not work for anybody else during the duration of the contract since he was on call 24h/24h; r)              since the Appellant was employed on an "on demand" basis for various periods in the year and was paid only for those periods, with no commitment for indeterminate employment or for a minimum number of days of employment in the year, he was then considered to commence and cease employment at the beginning and end of each such period; s)              throughout the 1997 taxation year, HMSI concluded an agreement with DOOR to hire the Appellant for the following periods:                 15/02/97 to 03/06/97: with the oil company "Katar Gas and Petroleum Co. ...

She also worked part-time for Parkdale Community Health Centre, for whom she would be required to make occasional house calls, although this was not considered by her as part of her developing psychotherapy practice. ... For the business to be considered a source of income or source of loss requires some element of a profit test. ...

However, the calculation of the percentage is not at issue and it must be considered that if the input-based method is used, what counts is that the percentage can reasonably be defended. [15] Yves Lacoste filed his audit report as Exhibit I-2 and various working documents as Exhibits I-1 and I-3 to I-9. ... The confirmation expressly stated that the agreement could not serve as a precedent and that each case would have to be considered individually. [21] Mr. ...

., [1997] A.Q. no 3951, the Court of Appeal of Quebec considered the meaning of "garantie" (the French version of security in subsection 317(2)) at paragraph 25: Ensuite, la définition encore plus large de "garantie" comprend tout droit sur un bien qui garantit l'exécution d'une obligation. ... Le cautionnement est une sûreté personnelle. [16] In common law, the word security has been judicially considered by the Supreme Court of Canada in The Queen v. ...

This work may be considered as constituting standard practice for persons with acceptable skills in computer science.... ... This work may be considered as constituting standard practice in the field of computer science.... ...

Drapeau has made new arguments that he says were not considered by those courts. ... Again the issue was whether the fact that the sums received were exclusively for the maintenance of the children deprived the recipient of the discretion that was necessary in order for these payments to be considered as allowances within the meaning of subsection 56(12) of the Act, and consequently should not be included in the custodial former spouse’s income under paragraphs 56(1)(b), (c) or (c.1) of the Act. ...

However, as stated by Robertson J.A. of the Federal Court of Appeal in Still, there is no express penalty for a breach of this provision. [5] At common law, a contract which is either expressly or impliedly prohibited by statute is normally considered to be void ab initio. ... Attorney General of Canada, [1983] 1 S.C.R. 2), he held that the underlying objectives of the restrictions provided for in the Immigration Act are not undermined if unemployment insurance benefits are granted to a person who has legally entered Canada and who moreover held employment which, had it not been for the employment authorization issue, would have been considered insurable within the meaning of the UIA. [9] In Robertson J.A.'s view, Ms. ...

It drew a distinction between inside and outside directors and stated that, in each of these two categories, a director's personal experience and role within the corporation must be considered. ... In the circumstances, she could be considered an inside director. Even if it were agreed that the appellant fell into the category of outside directors, she nevertheless had a duty, once she had become aware of the business's financial difficulties, to ensure that source deductions were remitted. ...

To formulate a decision then, the overall evidence must be considered taking into account those of the tests which may be applicable and giving to all the evidence the weight which the circumstances may dictate. ... The most that can be said is that control will no doubt always have to be considered, although it can no longer be regarded as the sole determining factor; and that factors, which may be of importance, are such matters as whether the man performing the services provides his own equipment, whether he hires his own helpers, what degree of financial risk be taken, what degree of responsibility for investment and management he has, and whether and how far he has an opportunity of profiting from sound management in the performance of his task. ...