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Insurers issue general fund annuity contracts (including segregated fund policies) which are considered to be insurance policies. ... Canada [21] the construction of a phrase used in the Excise Tax Act in the context of surface mining techniques was considered. The Court considered "ordinary meaning" versus "technical meaning" and concluded ordinary meaning may be rejected in favour of technical meaning where the persons being regulated would have understood the regulatory provision according to its technical meaning. ...

Inc. and Distribution F.H. for 1995, thus confirming the Appellant's testimony;   ‑ these drawings (debit column) were necessarily used for subsequent contributions (credit column), for the payment of debts, for the payment of credit cards, for the reimbursement of business expenses, for the purchase of assets that were considered in establishing the equity in "Distribution FH" or to establish the Appellant's balance sheet, and so on ... It is important to recall that the drawings from the business redeposited to his personal account were not considered in the adjustments since they were included in the withdrawals from his personal account.   60.    ... Thus, if we had not considered the reimbursements, the balance would be higher, resulting in an increase in net worth and additional income ...

They were told that they could never see a Cabinet paper but the material that they submitted would be considered in the Cabinet papers. ... This was sent in before the assessment but he still considered it to be his objection. [43]     With respect to the year 1987, he received no confirmation and therefore no Notice of Appeal was necessary. ... To force him into such a situation would be a further violation of his Charter rights. [124] The Court would recommend that the Minister make a Remission Order in favour of the Appellant for all of the years that he should have been considered to be a member of the Band and during which time he should have been given the same rights as all other members of the Band. [125] It is interesting to note that the Minister had initially agreed to make a Remission Order but subsequently decided against this. ...

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. ... 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 ... She herself considered at all times that she was an employee working as such for the Appellant and taking direction from her. ...

The Queen, 2001 DTC 5212), the Federal Court of Appeal considered paragraph 18(1)(e) and adopted the following test for determining whether a liability was contingent: I should define a contingency as an event which may or may not occur and a contingent liability as a liability which depends for its existence upon an event which may or may not happen.                                                     ... Borins J.A., writing for the Court, stated at page 5293: [34]       Following the reasoning of Pigeon, J. in Time Motors, the annual amounts which CP added to its account should not be considered apart from its statutory liability under the Workmen's Compensation Act. ... Once the scaling slips were presented to the taxpayers, the work of the contractors was considered complete. [20]       The taxpayers were aware that if they paid a contractor in full upon completion of its work, they might find later that the contractor had failed to make the required workers' compensation contributions. ...

In the course of her analysis, she considered the records of Brent Kelly Farms and/or Eagleview to be the most reliable because Nick Hothi – at Brent Kelly Farms- had verified the hours worked and the accuracy of the invoices submitted by Arun and it was not reasonable for those businesses to have paid Arun for workers who had never attended at the farms in order to supply labour. ... During interviews with workers, it was common for people to report working only 8 hours per day but Rai considered this response was routinely offered in order to avoid raising any issue of overtime pay or to cause further inquiry concerning a potential lack of compliance- by the employer- with labour standards under provincial law. ... Regulations 9.1 and 9.2 are as follows:   9.1  Where a person's earnings are paid on an hourly basis, the person is considered to have worked in insurable employment for the number of hours that the person actually worked and for which the person was remunerated.   9.2  Subject to section 10, where a person's earnings or a portion of a person's earnings for a period of insurable employment remains unpaid for the reasons described in subsection 2(2) of the Insurable Earnings and Collection of Premiums Regulations, the person is deemed to have worked in insurable employment for the number of hours that the person actually worked in the period, whether or not the person was remunerated ...

The PST arrears were considered to present a more pressing and potentially harmful problem than the amount owed in respect of GST and, in compliance with the adage, "the squeakiest wheel gets the grease", Birchard- on behalf of Dortec- began submitting monthly payments- in the sum of $1,700- to pay off the PST debt. ... Harvey Kalef, 96 DTC 6132, the Federal Court of Appeal considered whether the taxpayer had ceased to be a director upon the appointment of control over affairs of the corporation by the trustee in bankruptcy. ... McKinnon et al., 2000 DTC 6593. the Federal Court of Appeal considered the matter of directors' personal liability for unremitted source deductions and GST. ...

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. ... 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 ...   [42]     With respect to assumption (ll), the Appellant considered the $692.00 paid each 2 weeks to be a guaranteed base salary not an advance on future sales. ...

In response to a query as to whether she considered herself to be in business she replied in the affirmative saying that she didn't have to go to a job. ... 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 hired his own helpers, what degree of financial risk he takes, 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. [74]          Counsel stated that the Appellant had certainly grown but asked whether that was so for the Demonstrators. [75]          Appellant's counsel then turned to a submission based upon Regulation 6(g). ... 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. ...

Her Majesty the Queen, stated:...the following connecting elements are considered for determining the situs of the investment income: (a) the residence of the Appellants; (b) the origin or location of the capital used to buy the securities; (c) the location of the bank branch where the securities were bought; (d) the location where the investment income is used; (e) the location of the investment instruments; (f) the location where the investment income payment is made; and (g) the nature of the securities and in particular; (i) the residence of the issuer, (ii) the location of the issuer's income generating activity from which the investment is made, and (iii) the location of the issuer's property in the event of a default that could be subject to potential seizure. ... We should indicate that the concept of "commercial mainstream" is not a test for determining whether property is situated on a reserve; it is merely an aid to be used in evaluating the various factors being considered. ... Extremely important, particularly in this case, is the type of income being considered as attracting taxation. ...