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There are two elements here to be considered: the activity carried on for the Appellant and the activity carried on for others. ...

The route would be considered a rural route. Some routes, for example, urban routes, may be more profitable than others. ...

Several factors can be considered in order to detect the presence or absence of a relationship of subordination. ...

The worker stated that she had been dismissed by the Appellant because she wanted to be considered as an employee. ...

No. 316 ruled that the presumptions of the Minister must be considered admitted unless they are expressly refuted by the Appellant. [24]Consequently, the employment of the Appellant with the payors is excluded from insurable employment in accordance with paragraph 5(2)(i) of the Employment Insurance Act since, in accordance with paragraph 5(3)(b) of the same Act, the Appellant and the payors were related and it is not reasonable to conclude, having regard to all the circumstances, that they would have entered into a substantially similar contract of employment if they had been dealing with each other at arm's length. [25]For all these reasons, the appeals are dismissed and the decisions of the Minister are upheld regarding the insurability of the Appellant's employment. ...

Leduc considered standard practice, Mr. Sadlowski did not keep T2020's, preferring to maintain an electronic "log" of whatever he felt was noteworthy. ...

The comparison of the Intervener's status with that of the Appellant corporation's other employees is irrelevant. [59]     In conclusion, it appears from the evidence that the person handling the Appellant's case considered all the relevant facts and that the result of that person's analysis is entirely reasonable. [60]     The Appellant's main allegations, in particular that Pierre Moisan enjoyed considerable flexibility and independence and that he was engaged in a number of activities, such as construction, hunting, snowmobiling and administration, were neither relevant nor determinative. [61]     Based on the number of shares they held, Pierre Moisan's brother and brother-in-law could have intervened at any time to correct the situation, if it had not been consistent with the expectations of the corporation they controlled. [62]     The fact that they did not intervene does not in any way mean that they had waived that power conferred on them by their shares. ...

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.             ...

[24]     Paragraph 18(1)(a) of the Income Tax Act (the " Act ") provides that in order for a taxpayer to make a deduction from income, the deduction must be shown to have been made or incurred for the purpose of gaining or producing income from a business or property. [25]     In determining whether the Appellants could be considered to be carrying on a business the following points should be noted:-        The so-called "marketing expenses" were never paid and "marketing" never took place.-        Partnerships were never formed because neither Eizenga nor Sylvester (the principles of ABO) had the intention to carry on business in common with the investors.-        Eizenga and Sylvester represented to the investors that the partnerships would carry on the business of producing sound recordings, records and music and these representations were false.-        Eizenga and Sylvester marketed the partnerships as vehicles which would produce substantial tax savings. ...

A change in the taxpayer's mode and habit of work or reasonable expectations may signify a change in the chief source, but that is a question of fact in the circumstances. [16]     The manner in which Moldowan is to be applied was considered by the Federal Court of Appeal in The Queen v. ...