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The Respondent attempted to do so by specifying which of the outstanding items included in the Trust's estimate it considered to be allowable as expenses. ... My analysis does not end there, however, as other costs must be considered, including the exercise room, fencing, metal railings and other items disallowed by the Minister. ...

Whether the intermediary's service can be considered to be a service of arranging for a supply of a financial service is a question of fact depending on the degree of involvement of the intermediary in each particular case. ... Since there seems to be a difference in meaning between the two versions, the principles of interpretation regarding bilingual legislation must be considered. ...

Tanner stated he considered SPI was the proper entity responsible for remitting income tax and other source deductions as well as amounts due in respect of GST collected, since it had been responsible for paying wages and had issued all invoices- including GST amounts- to customers since December 1, 1997. ... He agreed the numbers therein pertained to both Specter and SPI even though he had not requested that sort of analysis from the bookkeeper because he wanted only to be provided with information that was relevant to Specter's participation in the business arrangement with SPI so he could have a better understanding of what had transpired during the period when Specter and SPI were operating what he considered to have been a joint venture. ...

" The answer is clearly no; however, there is cause to ask questions when the initial claims were that the cheques proved payment and receipt of salary. [26]     Generally, the Appellant and her husband, as agent of the Intervenor, provided all sorts of explanations that were ambiguous, confusing and inconsistent and, at the time, completely contradictory to support their fundamental claims that the Appellant had been paid and that she had not worked at all, or very little, from January to September during the years at issue. [27]     The only element that they emphasized as being clearly an error in the gathering of the data considered during the processing of their file was the question of the location where the business's deposits were made. [28]     The Respondent submits that they were made outside the small community where the business was located, whereas the uncontradicted evidence showed that they were made at the counter or at the Caisse Populaire in the municipality of Price. ... The lay-offs were planned and orchestrated for the sole purpose taking maximum advantage of the employment insurance program. [37]     First, the Appellant and her husband worked together in an irreproachable manner where it was a question of the insurable nature of the work; since there was already a favourable decision with regard to the work, they thus undoubtedly thought that they were protected from any problem. [38]     As the results of the investigation proved disastrous, they then clearly decided to argue using all sorts of far-fetched explanations, which the Appellant offered in a manner that was hesitant, confused, vague and riddled with inconsistencies and contradictions. [39]     There is no doubt that the Respondent conducted a proper analysis and considered all the relevant facts. ...

Subparagraph a) [5] means, therefore, that in the application of the Convention (that is, where there is a conflict between the laws of the two States) it is considered that the residence is that place where the individual owns or possesses a home; this home must be permanent, that is to say, the individual must have arranged and retained it for his permanent use as opposed to staying at a particular place under such conditions that it is evident that the stay is intended to be of short duration. 13.    ... Subparagraph a) means, therefore, that in the application of the Convention (that is, where there is a conflict between the laws of the two States) it is considered that the residence is that place where the individual owns or possesses a home; this home must be permanent, that is to say, the individual must have arranged and retained it for his permanent use as opposed to staying at a particular place under such conditions that it is evident that the stay is intended to be of short duration. 13.    ...

        [9]      Presumably since Towers Perrin considered that it was prohibited under the Pension Benefits Act from paying the full formula amount to Mr.  ...   [15]     The matter has been considered on a number of occasions in the courts. ...

Rhyannon Martin, an experienced claims examiner for Aviva, testified that a move from claims examiner to independent adjuster would be considered a "lateral move" where an employee wanted more flexibility respecting hours and work location. ... As already mentioned, the Minister assumed in support of his decision the existence of a number of facts obtained by inquiry from workers and the business he considered to be the employer. ...

RECONCILIATION OF THE NET WORTH STATEMENT FOR THE PERIOD FROM JANUARY 1, 1996, TO DECEMBER 31, 1999   1999 1998 1997 1996 Net value at the end $550,876.00 $522,518.00 $458,936.00 $400,682.00 Net value in the beginning   $522,518.00 $458,936.00 $400,682.00 $344,406.00 Increase in net value     $28,358.00 $63,582.00 $58,254.00 $56,276.00 ADD         Personal expenses $10,000.00 $10,000.00 $10,000.00 $10,000.00 Federal income tax $5,251.00       Provincial income tax $5,000.00       Quebec pension plan $1,504.00         $21,755.00 $10,000.00 $10,000.00 $10,000.00 Total increase     $50,113.00 $73,582.00 $68,254.00 $66,276.00 DEDUCT         Taxable sources         Total declared income of Hope Coulombe $606.00 $2,951.00 $1,250.00 $863.00 Total declared income of Lloyd Stutervant $18,479.00 $52,246.00 $29,666.00 $29,790.00 Taxable dividend gross-up         Taxable dividend gross-up of Hope Coulombe  -$481.00-$250.00-$3,277.00 Taxable dividend gross-up of Lloyd Sturtervant  -$4,327.00-$4,750.00-$172.00   $19,085.00 $50,389.00 $25,916.00 $27,204.00   Non-taxable sources         Capital dividend   $23,193.00     Exempt capital gain from the residence $11,000.00       Non-taxable portion of capital gain $4,750.00       Inheritance from his mother     $25,000.00 $25,000.00   $15,750.00 $23,193.00 $25,000.00 $25,000.00 Total reductions $34,835.00 $73,582.00 $50,916.00 $52,204.00 Actual unexplained difference in net worth   $15,278.00 0.00 $17,338.00 $14,072.00 Elements not considered by CRA         Capital cost of depreciable property disposed of at the auction of April 24, 1999 (Appendix attached)   $92,584.00       Inheritance from his mother, the documents for which  are difficult to obtain $50,000.00         $142,584.00 0.00 0.00 0.00 Difference in net worth calculated by CRA   $157,862.00 0.00 $17,338.00 $14,072.00 In summary, CRA taxes the property that was acquired before the period and disposed of during the period as well as the inheritance from his mother.     ... The Appellant traded these in when the Company made purchases in 1990, so they cannot be considered part of the Appellant's assets at 1995 year end. ...

This amount was set up as a loan to Proma but it repaid no amount of the loan. 105 was considered to be head of the group of companies or the tip of the pyramid and it made more sense to set up the loan from the bank through this corporate entity. 105 also loaned money to other companies in the Metal Group as can be seen from the document in Exhibit A-1 at Tab 12. ... They were considered to be loans by the Appellant. They were booked by the accountants as loans and they were listed in the company's books for accounting purposes as loans. ...

Any and all incidences [sic] of solicitation or forms of solicitation of a Teach & Embrace Corporation client during the timeframe of this contract will be considered a breach of contract causing damages to the "Corporation" equivalent to the value of the business in progress with said client; moreover, over and above the current value of the said business in progress, damages equivalent to one‑hundred [sic] dollars ($100) per day for the length of the breach of contract will be claimed of the "Tutor" who contravenes the stipulations herein of non‑competition. ... Preparation and travel time is at your own expense (and is considered an allowable expense). ·    If you are invoicing for one‑on‑one tutoring done in a client's home, please ensure that a parent or legal guardian has signed the attendance sheet. ...