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He argued that the reimbursements were in respect of amounts paid by Roberge as agent for the lease operators. [52]         The evidence before the Court does not support such a finding. [53]         The following definition of agency, by Gerald Fridman, has been quoted and applied in a number of Canadian cases: Agency is the relationship that exists between two persons when one, called the agent, is considered in law to represent the other, called the principal, in such a way as to be able to affect the principal's legal position by the making of contracts or the disposition of property. [20]   [54]         In view of this definition, the issues in this appeal are, as noted by counsel for the Respondent, whether the lease operators were liable under the relevant taxing schemes to pay the inter‑jurisdictional fuel tax and inter‑jurisdictional sales tax and whether, having that liability, they entered into an agency agreement with the Appellant to pay the taxes on their behalf. [55]         As the person who registered the leased vehicle with the Saskatchewan government under the IFTA program, Roberge was the person who was liable, under section 4 of the Saskatchewan Fuel Tax Act, for the inter‑jurisdictional fuel tax. [56]         Similarly, the inter‑jurisdictional sales tax provided for in sections 5.1 to 5.8 of the Saskatchewan Provincial Sales Tax Act was levied on the person who licensed the inter‑jurisdictional vehicle for use in Saskatchewan and one or more member jurisdictions. ...

If the contractor suspends the work for financial reasons, the work is generally not considered to have been completed (see J.A.  ...

The Minister of National Revenue has considered the reasons set out in your objection and all the relevant facts. ...

  [70]          In this case, there were not very many facts to be considered; clearly, there would have needed to be more facts gathered from the investigation. ...

In this view, “the day of … original assessment” referred to in Section 46(4) was in the present case May 28, 1953, and it remains to be considered whether the re-assessment under appeal was made within four years from that day.  ...

For paragraph 251(1)(b) to apply, the transferor has to be either the trust created by the will or the estate, a trust and an estate being considered one and the same by virtue of subsection 104(1) of the Act. ...

The Company does not have an established history of actual operations of its current business upon which an investor can base an investment decision, and the likelihood of success of the Company must be considered in view of all of the risks, expenses and delays inherent in establishing, operating and expanding a new business, including, but not limited to, unforeseen expenses, complications and delays, the uncertainty of market acceptance of new services, intense competition from larger, more established competitors and other factors.   ...

Further, the longevity of the relationship should be considered. The longer the relationship has endured, the chances of finding a proprietary interest is more compelling ...

  [48]          It is accepted that, while not determinative, the views of the administrator have some weight and may be considered. [24] It is also accepted that, while not determinative, Technical Notes are entitled to consideration. [25]   [49]          In the 2009 Canada Revenue Agency (the “CRA”) publication, GST/HST Information for Municipalities, it is stated:   A supply of a service of installing, repairing, maintaining or interrupting the operation of a water distribution, sewerage, or drainage system, is not subject to GST/HST if the supply is made by a municipality or by an organization designated as a municipality for this purpose.   ...

Maarten, Netherlands Antilles part of the address was used because he had once visited the Netherlands Antilles with his wife, and they had considered buying a timeshare unit there. ...