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I have considered a decision of this Court by Judge Porter in Thomson Canada Ltd. ...

I have carefully considered the testimony regarding the use of the vehicles and I have concluded that the Appellant should be allowed to claim the following motor vehicle expenses.                                                   2000                       2001             Recreational Vehicle        75%                      75%             Suzuki                            70%                      70%             The above percentages also apply to capital cost allowance on the vehicles.   6.       ...

In order to resolve this question, which has been variously characterized as fundamental, central, and key, the total relationship of the parties and the combined force of the whole scheme of operations must be considered.                  ...

Essentially, the appellant argues that during the years in question his work in Québec City was "of a temporary nature", his place of work at Le Soleil must be considered to be analogous to a "special work site" and he always maintained his principal place of residence in Domaine Cherbourg, in Orford township in the Eastern Townships. ...

[23]     It has been established that Daniel Bernard's two brothers, who were each responsible for one shift (one for the sawing of pine and the other for the sawing of spruce), had salaries that were, all things considered, comparable to Daniel's salary. ...

  [22]     Work that is excluded in principle will be considered insurable if it is reasonable to conclude, having regard to all the facts and circumstances of the employment, that a substantially similar contract of employment would have been entered into if the persons concerned and the business had been dealing with each other at arm's length ...

Huber considered herself a fulltime employee of Starsky. When she met with the manager to sign some preliminary paperwork, she indicated that she was looking for fulltime employment. ...

  [30]     In other words, the review that led to the settlement was the result of considerations of relevant elements and facts that were considered relevant; nothing more and nothing less ...

  [17]     In my opinion, the income tax laws of any country would not be considered to be statutory laws of general application for the purposes of the application of the lex fori to any unproven tax laws of a foreign jurisdiction, and therefore the provisions of the Act and the Income Tax Regulations should not be applied to fill in any gaps missing from the US tax laws that have been established at the hearing. ...

While the University believed they were administering the program in compliance with Income Tax Regulations, CRA’s position was that this benefit should be considered taxable in the hands of the employee of Western, not the student receiving the scholarship. ...