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These factors should then be analyzed to determine what weight they should be given in identifying the location of the property, in light of three considerations:  (1) the purpose of the exemption under the Indian Act; (2) the type of property in question; and (3) the nature of the taxation of that property.  ... However, this approach has the advantage that it preserves the ability to deal appropriately with future cases which present considerations not previously apparent. [7] The cases in which the principle has been applied necessarily turn on their specific facts. ...

[36]     In general, the test requires a consideration as to whether confidential information was received at an old law firm and whether there is a risk that it will be used to the prejudice of the client at a new law firm ... In my view, mobility for legal assistants is an important consideration to be taken into account ...

Theoretically one might, in a connected series of events leading to a predetermined conclusion, postulate as the purpose of each event in the sequence the achievement of the result that immediately follows but in determining the "purpose" of the use of borrowed funds within the meaning of paragraph 20(1)(c) the court is faced with practical considerations with which the pure theorist is not concerned.                                                                                            ... A as consideration for this buy-back and Ms. A uses the proceeds to pay off the Promissory Note she issued on the purchase of the property the day before; ·         The proceeds from the Promissory Note are used by the Appellant to pay off the first bank loan; ·         The only remaining loan is the second loan taken to acquire a rental property; ·         Everything is done at fair market value without tax consequence, and actual transfers of land need never be registered ...

  [7]      The issues are as follows:             (a)   whether the Appellant collected GST as consideration for the commissions he billed to GR and as consideration for the supply of other goods and services not related to GR;           (b)   whether, if the GST was collected by the Appellant, that tax had to be remitted to the Minister by the Appellant; and           (c)   whether the Appellant is entitled to the amount of $2,449.57 as input tax credits that he previously claimed and obtained for the quarters ending on September 30, 1999, and December 31, 1999 ...

I fail to see how Arthur Andersen’s working paper files or their considerations in producing the report are relevant ... The Appellant has now asked as a follow up question that the Respondent provide all facts, information and documents relating to CRA’s considerations and conclusions on the issue discussed in the document ...

Following Royal Winnipeg Ballet, intention is an important consideration and in this case clearly leans in favour of employment.   ... This consideration also inclines in favour of an employment relationship.   ...

The Queen 2000 DTC 6061, [2000] 2 C.T.C. 1, the Federal Court of Appeal made the following comments in relation to the test that should be used to determine whether the buildings in that case were “used primarily for the purpose of manufacturing or processing goods for sale”:   14        In accordance with Mother's Pizza, use of the space in the buildings is the most important consideration in determining the use primarily made of the buildings. However, that does not exclude other considerations and we are prepared to assume, without deciding, that in a case such as this, a qualitative assessment is also relevant. ...

There are three important considerations when determining the weight of connecting factors: the purpose of the exemption [9]; the character of the property in question; and the incidence of taxation upon that property. [10] 3.      ... Another significant consideration is whether the income earned was integral to the life on the reserve and should be protected to prevent the erosion of the property held by Natives qua Natives.   ...

The relevant considerations in making this determination are set out by the Supreme Court of Canada in the Sagaz decision cited by counsel for the respondent at paragraph 47.  ... Another consideration is the intentions of the parties to the contract.  ...

If NRM acted as agent, it could be argued that none of the consideration was contingent because NRM paid for the entire investment by way of cheque. The appellant did not take this position, however, and acknowledged that the promissory notes were part of the consideration for the seismic data. [2] Based on the pleadings, it is arguable that the Crown should have the onus to establish that the appellant did not acquire the seismic data. ...