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Another consideration was the nature of the dispute which gave rise to the refund (reasons at para. 27):   It is also useful to look at the nature of the issues in the tax dispute that led to the refund, namely, the issues on which the [respondent] was successful. ...

When these findings are referred to in the following analysis of the decision under appeal and of the parties’ arguments, some of the grounds of appeal will emerge for consideration. ...

In the context of the exemption from taxation in the Indian Act, there are three important considerations: the purpose of the exemption; the character of the property in question; and the incidence of taxation upon that property.  ...

In Stewart, above at para. 51, the Supreme Court of Canada, briefly touched upon the relevant considerations: Equating "source of income" with an activity undertaken "in pursuit of profit" accords with the traditional common law definition of "business", i.e., "anything which occupies the time and attention and labour of a man for the purpose of profit": Smith, supra, at p. 258; Terminal Dock, supra. ...

Value of passenger vehicle   For the purpose of determining an input tax credit of a registrant in respect of a passenger vehicle that the registrant at a particular time acquires, imports or brings into a participating province for use as capital property in commercial activities of the registrant, the tax payable by the registrant in respect of the acquisition, importation or bringing in, as the case may be, of the vehicle is deemed to be the lesser of   (a) the tax that was payable by the registrant in respect of the acquisition, importation or bringing in, as the case may be, of the vehicle; and   (b) the amount determined by the formula   (A x B)- C   where   A is the tax that would be payable by the registrant in respect of the vehicle if the registrant acquired the vehicle at the particular time   (i) where the registrant is bringing the vehicle into a participating province at the particular time, in that province, and   (ii) in any other case, in Canada   for consideration equal to the amount deemed under paragraph 13(7)(g) or (h) of the Income Tax Act to be, for the purposes of section 13 of that Act, the capital cost to a taxpayer of a passenger vehicle to which that paragraph applies,   …   C is … zero.   123. ...

This conclusion is obvious, especially if I take into consideration the numerous hours of unpaid work performed by the employee during the low season.     ...

As consideration for those payments, Ms. Lister obtained the right to occupy an apartment, two prepared meals each day in the dining room, a 24 hour emergency call system and health monitoring with a personal pendant, medical supervision to assist her with medication four times a day, assistance with puffers, and laundry and housekeeping services. [3]                Hawthorn Park also had a residence called Orchard Manor that was equipped to provide secure facilities and 24 hour nursing care for persons suffering from Alzheimer’s disease or dementia. ...

The Directive that incorporates the Policy identifies a number of factors that may be taken into consideration for a request for an extension of time, such as extraordinary circumstances (death, flood, fire), reasonable efforts to comply with the Act, failure by the Canada Customs and Revenue Agency (Agency) to act on a written request for information, delay by the Agency in providing the information requested, etc. ...

  [23]            This now brings me to a consideration of the material upon which the third review decision was made ...

A cheque was made payable to the Appellant and deposited to its Royal Bank account; and   On May 15, 1993, Woodwards transferred its interest in the Partnership to the Appellant for $1.00 and other good and valuable consideration;   For the April 30, 1992 fiscal year-end of the Partnership Woodwards was allocated operating income for accounting purposes of $11,563 out of a total of $292,066. ...