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Bourdages explained that the members were considered self-employed until the late 1980s. ... This caused problems for certain workers, who had considered themselves self-employed and had claimed deductions on their tax returns accordingly. [13]     Claude Fettaya, the president of Intervener Géo Tours Inc., testified that the Appellant did not return at least one of his calls offering him a tour. ...

By letter, Exhibit A-5, the Appellant was advised that pursuant to section 9.1 of the Employment Insurance Regulations 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. ... It is clear from the provisions of section 2 of the Insurable Earnings and Collection of Premiums Regulations, Part 1, that in order for an amount to be considered to be earnings for insurable employment the amounts have to be paid to the person by the person's employer in respect of that employment. ...

Paragraphs 45 and 46 of her reasons read: ARREARS: [45]       1999 Support-Related Amounts Payable- Having considered the evidence, I estimate that in 1999, Mr. ... It is paid to the appellant to enable her to cover her living expenses. [14]     The meaning of "allowance" was considered by the Supreme Court of Canada in Gagnon v. ...

In his view, the accused must prove six elements:   (1)        that an error of law or of mixed law and fact was made; (2)        that the person who committed the act considered the legal consequences of his or her actions; (3)        that the advice obtained came from an appropriate official; (4)        that the advice was reasonable; (5)        that the advice was erroneous; (6)        that the person relied on the advice in committing the act.   ... This aspect of the question must be considered from the perspective of a reasonable person in a situation similar to that of the accused. ...

All three sales are considered to be current to the effective date and no adjustment to their sale prices was required.   ... Sales 1 and 2 are considered to be inferior to the subject. The subject’s estimated value must therefore be above the highest price indicated by these two sales, in this case, above $120 per square foot. ...

According to the appellant, because he considered that he continued to operate the business as a motel, he felt that he was required to remit both taxes even though he did not charge the taxes on long-term rentals. ... At least two situations occur to me where a claim by a supplier might be considered: (a)         where a supplier does not collect GST from a recipient in respect of an exempt or zero-rated supply and then, erroneously, remits from its own funds an amount as GST to the government. ...

Stanfield be considered together.   a)       Stay Application   [13]     Respondent's counsel opposed the application to stay the appeals of the Other Appellants. ... Also, a section 163(2) penalty is of a personal nature, since knowledge or gross negligence is a key component of the penalty, and therefore each appellant's action or intention with respect to the facts leading to the individual's penalty must be considered separately ...

Dunbar's activities, however, be considered OSL's activities, such that it is OSL who is carrying on business outside Canadawith respect to the exploitation of petroleum? ... If, however, the business is providing services by way of subcontracting to a contractor, which services must necessarily be provided outside Canada, then the business can be considered to be carried on outside Canada. ...

Bergeron testified that he considered the following explanations by the appellant not very credible:             (i)      that the cash obtained from eight withdrawals [1] (in amounts varying between $350 and $1,050) totalling $5,400 had been used as partial payment for the "Harley" motorcycle acquired on August 18, 1998;             (ii)      that the cash obtained from two withdrawals, each in the amount of $3,000, [2] had been used as partial  payment for the snowmobile acquired on January 29, 1999; and             (iii)     that the cash obtained from eight withdrawals [3] (in amounts varying between $300 and $600) totalling $3,450 had been used as partial payment for the snowmobile acquired on December 14, 1999 ... Bergeron testified that he considered the following statements by the appellant not very credible: (i) that on November 4, 1999 he had received $5,000 cash from the sale of the snowmobile acquired in 1997; (ii) that he had used part of the proceeds of the sale ($450) for personal expenses; and (iii) that he had used the rest of the proceeds of the sale ($4,550) as partial payment of the purchase price ($8,000) of the snowmobile acquired on December 14, 1999 ...

., the principal and interest were therefore to be considered as being an amount owed to the Appellant;     e)         The financial statements of the company Les Habitations Durab Inc. for the fiscal periods ending on December 31, 1999 and December 31, 2000 clearly show as liabilities loans in the amount of one hundred and twenty thousand dollars ($120,000) which were in fact taken out personally by the Appellant;   f)          It is in error that the loans totalling one hundred and twenty thousand dollars ($120,000) appear in the financial statements of the company Les Habitations Durab Inc., since these should have been shown as an amount owed to a director, bearing interest at the rate agreed to with the Caisse populaire Desjardins du Vieux-Québec;   g)         As can be seen in the calculation document Exhibit A-6,  Louise Laroche, the Respondent’s employee, acknowledged that the sum of one hundred and twenty thousand dollars ($120,000) owed on the houses in stock should have been applied against the advances owed by the Appellant to Les Habitations Durab Inc.;   h)         The Respondent’s employee erred however, since she should have applied in favour of the Appellant personally, a credit of one hundred and twenty thousand dollars ($120,000), and that from the date when the latter took out these loans, namely from July 11, 1997, as well as all the interest that the latter paid on the said loans, since this amount was as a matter of fact borrowed on that date and was owed to the Appellant from that date;   i)          If the Respondent had correctly credited to the Appellant the amounts that were owed to him as principal and interest from July 11, 1997, the assessments with regard to the interest demanded from the Appellant would have been null ... It always considered the mortgage as its own debt.   [12]     The financial statements (Exhibit A-14) show that the amounts [TRANSLATION] “Advances without interest to a director” at the end of 1999 and 2000 are $ 134,395 and $108,416. ...