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Pauzé considered the reimbursement of his expenses to be a form of pay is a very revealing indication that he may have been mistaken as to the tax treatment of the money paid to him by Référium. [9] Furthermore, I have no doubt that Référium really intended to pay its sole shareholder a dividend. ...

According to the appellant's testimony at page 36 of the transcript, those were the only expenses that had to be shared by the partners. [13]     As the appellant explained, the partners could each personally, depending on how motivated they were, incur the expenses they considered useful to earn "royalties" paid by Titrex. ...

Millar testified that his personal car was a 1977 Lincoln, which, because of its age, he considered to be unreliable for use on business trips that took him away from the City of Edmonton. ...

Subsection 3(2) lists what is considered "excepted employment" for the purposes of the Act. ...

Other factors were considered to come to the negotiated result, including the doctor built into the hourly rate compensation for the use of his premises, his equipment, his receptionist and allocation for the reception area in the offices that he provided. ...

He submitted that he considered this to be a basis for reassessment by the Minister of National Revenue ("Minister") because paragraph 6(e) of the Reply to the Notice of Appeal, setting forth "assumptions of fact" made by the Minister stated: As of May 1, 1991, the fair market value of the Northeast Quarter was for the most part dependant upon the value of the deposits of limestone contained under the surface of the property. ...

Hausmann was a social security pension within the meaning of the treaty appears not to have been considered. [17] I start with the Income Tax Act. ...

Gähwiler considered entering into a variety of financial relationships with Mr. ...

I am further satisfied that the corporation, by reason of the foregoing, should be considered as having sold (or exchanged for parts) those vehicles with the result that the amount of $18,894 should have been included in the corporation's gross income. ...

His evidence was clear that these factors were considered when Revenue Canada was devising the proper formula for the assessment of tips. [9]        Counsel for the Respondent was clearly correct when he cited the various sections of the Income Tax Act (the Act) which say that it is the duty of the taxpayer to keep records, to establish and report to Revenue Canada what their income was in the year under appeal. ...