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Since related persons, pursuant to paragraph 251(1)(a) of the ITA, are considered not to be dealing with each other at arm's length, the worker had a non-arm's length relationship with Monica Turcotte as common-law spouse and sole owner of the business she operated as "Bar Le Villageois 2004 Enr. ...

These circumstances must be taken into account, but must be considered against an objective "reasonably prudent person" standard. ...

(v)                 the Appellant's compensation was based on a 40-hour work week although she worked more; (admitted)   [36]          The evidence showed that all the facts considered and assumed to be true were entirely well founded. ...

Given that Parliament did not provide for a deduction under the OASA, the ITA’s treatment of the payment determines whether or not it is included in the income to be considered in the calculation of the OASA Supplement.   ...

Federal Commissioner of Taxation [6] that the answer to the question whether an outlay is to be considered capital or current in nature   depends on what the expenditure is calculated to effect from a practical and business point of view rather than upon the juristic classification of the legal rights, if any, secured, employed or exhausted in the process.   ...

You can see that some of them are in a variety of different modes, some of them were painted and finished or [sic] you could be considered finished. ...

  [64]          On the question of due diligence, he considered in his own mind that since the input tax credits from Bell Canada to the numbered company would offset the tax bill, there would be no Goods and Services Taxes owing. ...

  [69]           In the Chrapko case, the Federal Court of Appeal considered both racetracks to be the normal place of work, even though they were some distance apart. ...

  [3]      In order to resolve the question as to whether the five gentlemen are employees or independent contractors, the total relationship of the parties and the combined force of the whole scheme of operations must be considered. ...

  [31]           However, where the taxpayer has not served any written notice that can be considered an objection, there is no support in the case law for finding a valid notice of objection was given ...