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Generally speaking the intention is to be ascertained from the entire course of conduct and relevant circumstances and the inferences flowing therefrom. 5) Evidence of transactions of the sale and purchase of real estate by an appellant after the years under review in an appeal is admissible. 7) If an individual who is an appellant has a history of trading in real estate or if the appellant is a corporation that is controlled by such a person, this is a relevant consideration which points away from the purchase in issue being made with the primary intention of securing an income-producing asset. ... The records also showed that the defendant company was consistently adjusting its salaries and bonuses so that the net profit remained just below the amount at which a higher tax rate would have been payable which, in the Court's judgment, made it clear that tax considerations were important. ...

In connection with that business RML appeals three Canada Pension Plan (CPP) and three Employment Insurance Act (EIA, EI) assessments. [2] In raising these six assessments the Minister of National Revenue (Minister) took into consideration gratuities left by dining patrons through credit and debit card payments, i.e. electronic tips, for servers employed at RML’s restaurant. ... In that matter the SCC had for consideration gratuities that Canadian Pacific Ltd. ...

In addition, the fact that the requests may involve substantial documentation which the taxpayer may view as not proportional to the matter is not a relevant consideration (para 42). ... The course of an audit is directed by a multitude of factors, including the auditors’ experience, training, the state of the records, the tax history of the taxpayer as well as considerations external to the particular taxpayer. [20] The Respondents point to their financial difficulties, but the evidence to support that claim is lacking. ...

., does the plaintiff’s case have the ring of truth about it such that it would justify consideration by the trier of fact? ... The responding party also bears an evidentiary burden to put evidence before the court showing the existence of issues requiring a trial (rule 20.04(1)). — The court must look at the overall credibility of the respondent’s pleading and determine whether it has a “ring of truth” about it that justifies consideration by a trier of fact. — Where there are significant facts in dispute, the case should likely be sent to trial. ...

On cross-examination, Hick responded affirmatively to the question of whether the total amount of cash dividends was part of the consideration that the Appellant received for selling its shares. ... When asked by counsel whether the possibility of a tax advantage affected his decision about the determination of total consideration to be offered to the Appellant, James said, Absolutely not. ...

On a plain reading, the section will not be applicable where there exists no intention by the taxpayer to avoid receipt of funds in his hands by arranging payments to be made without adequate consideration to third persons. ... Subsection 56(2) of the Act reads as follows: 56.... (2) Indirect payments.- A payment or transfer of property made pursuant to the direction of, or with the concurrence of, a taxpayer to some other person for the benefit of the taxpayer or as a benefit that the taxpayer desired to have conferred on the other person (other than by an assignment of any portion of a retirement pension pursuant to section 64.1 of the Canada Pension Plan or a comparable provision of a provincial pension plan as define in section 3 of that Act or of a prescribed provincial pension plan) shall be included in computing the taxpayer’s income to the extent that it would be if the payment or transfer had been made to him. 2 Subsection 15(1) of the Act reads as follows: 15(1) Benefit conferred on shareholder. — Where, in a taxation year, a benefit has been conferred on a shareholder, or on a person in contemplation of his becoming a shareholder, by a corporation otherwise than by (a) the reduction of the paid-up capital, the redemption, cancellation or acquisition by the corpora tion of shares of its capital stock or on the winding-up, discontinuance or reorganization of its business, or otherwise by way of a transaction to which section 88 applies, (b) the payment of a dividend, (c) conferring on all owners of common shares of the capital stock of the corporation a right to buy ad ditional shares thereof, or (d) an action described in paragraph 84(1)(c. 1), (c.2) or (c.3), the amount or value thereof shall, except to the extent that it is deemed by section 84 to be a dividend, be included in computing the income of the shareholder for the year. 3 Subparagraph 69(l)(b)(i) of the Act reads as follows: 69(1) Inadequate consideration. — Except as expressly otherwise provided in this Act, (b) where a taxpayer has disposed of anything (i) to a person with whom he was not dealing at arm’s length for no proceeds or for proceeds less than the fair market value thereof at the time he so disposed of it, or... ...

Karavos was the beneficial owner of 25 per cent of the property from the time of its purchase in 1977 to the time of its disposition and subsequently was the beneficial owner of an equivalent portion of the mortgage received as consideration. ... By way of example, there is not a tittle of evidence that when the restaurant business was sold for $110,000 in 1981, consideration was given by the appellant or his wife to an apportionment of the gain arising from this sale. ...

What is germane to this appeal in subsection 160(1) of the Act provides that where a person has, on or after May 1, 1951, transferred property to his spouse the transferee and transferor are jointly and severally liable to pay an amount equal to the lesser of the amount by which the fair market value of the property at the time it was transferred exceeds the fair market value at that time of the consideration given for the property and the aggregate of all amounts that the transferor is liable to pay under the Act in or in respect of the taxation year in which the property was transferred or any preceding taxation year. ... The consideration was $37,000. On April 20, 1982, Linco transferred this property to the Linkes as joint tenants. ...

Considerations in Determining when an Experimental Development Project is Complete 7.1 The development of a new or improved product or process through a program of experimental development can be conceptualized as occurring in five stages: (1) The definition of a concept or technological hypothesis together with a statement of corresponding technological objectives. (2) The definition of a systematic program to achieve the technological objectives defined in (1). ... The future consideration of the taxpayer's intention with respect to the capital equipment seems irrelevant, especially in light of subsections 37.1(3) and (4) which refer to the disposition of research property in the specific taxation year. ...

Wilson agreed not to leave Magil in 1985 on account, among other considerations, of his long association with the latter firm and Mr. ... Wilson himself, given the fact among other considerations, that these appeals involved a corporate appellant. ...