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TCC

Macleod v. R., [1999] 4 CTC 2223 (Informal Procedure)

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. ...
TCC

Woessner v. R., [1999] 4 CTC 2337, 99 DTC 1039

Webster’s Ninth New Collegiate Dictionary: Full-time: employed for or involving full time (- employees) (— work) Full time: the amount of time considered the normal or standard amount for working during a given period. ...
TCC

McDonald v. R., [1999] 4 CTC 2459 (Informal Procedure)

He considered himself to be retired. Grant admitted that by mid-1993 Channel One began to fall behind in its withholding remittances to Revenue Canada. ...
TCC

Bâtiment Fafard International Inc. v. R., [1999] 4 CTC 2723, [1999] DTC 1206

The question of whether the transferee may challenge the validity of the transferor’s assessment has been considered by this Court on several occasions. ...
TCC

Lemmex v. R., [1999] 4 CTC 2790, 99 DTC 1197

I have difficulty in accepting volume of work in preparation considered alone, or in conjunction with such factors as the difficulty or importance of the case, as constituting a basis for exercising the judicial discretion to increase Tariff B costs items. ...
TCC

Groupe Immobilier Grilli inc. v. The Queen, 2019 TCC 223

Canada, 2011 FCA 234). [34] This issue must be considered in the context of the company operated by the taxpayer. ...
TCC

Adboss, Ltd. v. The King, 2022 TCC 125, aff'd 2023 FCA 201

Canada, 2010 FCA 309 [Fundy FCA] at para 56). [23] The case law is therefore clear that the common law test for determining the residency of a corporation is where its “central management and control” actually abides and various factors need to be considered to make that determination, including, generally, where the directors exercise their management and control. ...
TCC

1410109 Ontario Ltd. v. The King, 2022 TCC 141 (Informal Procedure)

Advocates general are considered advisers to the court and do not participate in the court’s decision-making process. ...
TCC

Gagnon v. The King, 2022 TCC 139 (Informal Procedure)

Further, these decisions are not particularly consistent; however, they do fall into two identifiable lines of cases. [22] The first line of reasoning holds that since a taxpayer has an alternative, safer method to calculate instalment payments, namely that proposed by the Minister or the previous year method (which considered a previous section of the Act), the taxpayer should do so. ...
TCC

Liberty Street Management Inc. v. The King, 2022 TCC 127

Canada, 2010 FCA 309 [Fundy FCA] at para 56). [23] The case law is therefore clear that the common law test for determining the residency of a corporation is where its “central management and control” actually abides and various factors need to be considered to make that determination, including, generally, where the directors exercise their management and control. ...

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