Search - consideration

He searched the data bank for additional documents on or about September 25, 1996 to find additional documents dealing with facts similar to those in the appellant's appeal where there was a consideration of GAAR. ...

Or, outre le degré de contrôle exercé par l’employeur, les facteurs habituellement pertinents à prendre en considération comprennent les points de savoir si le travailleur « fournit lui-même son outillage, engage ses assistants, gère et assume des risques financiers, et peut escompter un profit de l’exécution de ses tâches » (1392644 Ontario Inc c Canada (Revenu National), 2013 CAF 85, para 41 [Connor Homes], para 41). ...

Jones (19 August 2014) Questions 183 to 205 inclusive and answers. [24] The latter involves considerations involving the rule against hearsay and exceptions to that rule. ...

However, after careful consideration, I conclude that the Accountant's testimony is credible. ...

Other considerations are also present and clearly seen, but the possibility of these future qualified employees being recruited must not be disregarded. [56] In his testimony, Mr. ...

As mentioned in the Commentary of the United Nations Model Convention:...while interest on deferred-payment or credit sales should be considered in the context of the treaty article on interest, the nature of that consideration and the final resolution should be settled through negotiations between the parties. 63. ...

Counsel for the appellant stated in writing that the game records from the Full Tilt Poker website were not available and that he and his client would not take steps to obtain the above‑mentioned records from the other gambling websites. [74] The appellant’s unreported business income was determined using the net‑worth method following an audit of the appellant’s personal bank records; his credit card statements; the Equifax report; the land register in relation to the residence that the appellant had acquired, which was located at 3637 Robert‑Lepage Street in Quebec City; the appellant’s file at the Société d’assurance automobile du Québec; various interviews given by the appellant; and other information about the appellant that was available on the Internet. [75] The appellant’s net worth was compiled following consideration of a document entitled “ Sommaire de l’actif et du passif à partir de février 2012 ” ([translation] “summary of assets and liabilities from February 2012”), which the appellant’s counsel submitted at the initial interview with the appellant. ...

Since the 2 012 allowance i s not exc l uded from 2013 inc o me by virtue o f subparagraph 6(1)(b)(v), the n subparagra p h 8(1)(f)(iv) whic h precludes deductions only where subpa r agraph 6(1)(b)(v), is engaged, does not g et triggered either. [51] This type of probl e m invites a consideration of the purpose o f sections 5, 6, and 8 o f the A ct. ...

Specifically subsection 18.15(3) provides that: (3) Notwithstanding the provisions of the Act under which the appeal arises, the Court is not bound by any legal or technical rules of evidence in conducting a hearing and the appeal shall be dealt with by the Court as informally and expeditiously as the circumstances and considerations of fairness permit. and b) I am mindful that the CRA took eight years to process the appellant’s notice of objection. ...

That scenario is too remote to merit consideration because: No argument was presented as to how, as a matter of law, such a scenario could arise in this case; and There was no evidence that Petro Uno was in financial difficulty. [74] In his evidence, Mr. ...