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What is contemplated is a profit-making process consisting of such physical acts and the disposition of the products for a consideration by sale or otherwise. ...

Analysis   [13]            The Minister’s submissions, described below, raise three questions for our consideration:   (1)        What is the jurisdiction of the Federal Court on an ex parte application under subsection 231.2(3) and on a review under 231.2(6)?   ...

  [19]          So, although the counterletter establishes the true agreement between the parties, and while the tax authorities are required to take it into consideration when making an assessment (see also Transport Desgagnés v. ...

I noted above that the Crown, as part of the consideration for the cession of Indian lands, often committed itself to giving goods and services to the natives concerned. ...

At most, the taxpayer claims, it was a lessor of heavy equipment for which it received substantial consideration. ...

Taking all of this into consideration, a benefit of approximately 10% could be realized. [7]      All this evidence was provided by one of the Incotel investors, a Mr. ...

Surprisingly, without any evidence of any further consideration being given to the issue, CRA assessed the wives as de jure directors and did not assess the husbands as de facto directors. ...

The application of subsection 227.1(3) to the facts of this case and the relevant jurisprudence I turn now to a consideration of the applicable authorities and to the facts at bar. ...

In this context, "rate" could mean either the rate of CCA that is allowed by the Regulations for each class of depreciable property, or the rate at which CCA was taken by the taxpayer in question on a class of his depreciable property, which rate may, in fact, have been less than the maximum rate permitted by the Regulations since CCA is a permissive deduction and a taxpayer can choose whether or not to take CCA which is available to him in any year. [35]A reading of the French version of subparagraph 5401(1)(a)(ii) does not assist in deciding what meaning to attribute to the words under consideration since the French version contains the same ambiguities as the English version. ...

The Queen, [1986] 1 F.C. 346 (F.C.A.). [17]      However, these considerations cannot justify the interpretation of the definition of Canadian exploration expense proposed by the respondents. ...