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TCC

Waldron v. The Queen, docket 98-1822-GST-I (Informal Procedure)

Detriment to such person as a consequence of the act or omission. [2] [7] The issue of estoppel has been considered in a number of cases and the principle which generally can be taken therefrom is that no representation involving an interpretation of law by a servant or officer of the Crown can bind it. ...
TCC

Greenstreet v. The Queen, docket 97-1470-IT-I (Informal Procedure)

Generally a loan made by a person who is not in the business of lending money will be considered to be an investment. ...
TCC

E.R. Design Ideas Inc. c. The Queen, docket 97-2914(GST)I (Informal Procedure)

As the later figure is known to be generous as it would include personal expenditures of Phil Rosen, the adjustment will not be considered without an agreement to the assessment not being challenged. [13]     Mr. ...
TCC

Stephens v. The Queen, docket 98-478-IT-I (Informal Procedure)

I have considered the other criteria set out by the Federal Court of Appeal in Landry v. ...
TCC

Payne v. The Queen, docket 97-3468-IT-G

Subsection 146.01(2) clarifies the meaning of "acquires": (2) Special Rules For the purposes of this section (a) an individual shall be considered to have acquired a qualifying home if the individual acquired it jointly with one or more other persons; In order for Genevieve Payne to benefit from the Home Buyers’ Plan she had to acquire – alone or jointly – a qualifying home. ...
TCC

Gaudreau & Associés, Avocats, S.E.N.C. v. M.N.R., docket 98-59-UI

Hamel considered Mr. Gaudreau to be his supervisor. Mr. Hamel generally worked from 8:00 a.m. to 7:00 p.m. ...
TCC

Hirst v. The Queen, docket 98-682-IT-I (Informal Procedure)

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. ...
TCC

Chevarie v. M.N.R., docket 98-700-UI

Furthermore, while the Notice of Appeal was drafted as though it concerned a single decision, the respondent himself recognized and admitted that he considered the said Notice as valid in respect of two decisions. [16] In the circumstances, the Department of National Revenue should accept the Notice of February 12, 1998 as an application for review of the decision of January 9, 1998, particularly since it undoubtedly concerned a similar employment held during a proximate period. ...
TCC

Chantler Packaging Inc. v. M.N.R., docket 98-50-UI

In the summer of 1993 his fixed annual salary and automobile allowance were gradually phased out with a corresponding increase in sales commission up to 6% of his sales; since he was no longer considered to be an employee, the cheque for his remuneration of the sales commission included an amount for GST but was no longer subject to the usual deductions for income tax on premiums for unemployment insurance and Canada Pension Plan. ...
TCC

Strachan v. The Queen, docket 98-1914-GST-I (Informal Procedure)

Therefore, individuals pursuing a hobby or a business with no reasonable expectation of profit will not be considered to be engaged in a commercial activity for the purposes of the Act. ...

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