Search - consideration

The standard to be applied is one of reasonable consideration. But it is clear that the proper approach to applying paragraph 55(1)(c) of the Act requires that one views the transactions as a whole rather than in isolation. ...

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). ...

In addition, there are other cases involving consideration of the decision in which the Income Tax Appeal Board dismissed the taxpayer’s appeal and he brought an appeal from its decision to this Court. ...

With these considerations in mind, I proceed to consider the facts applicable to each of the years under review. ...

The factor of space is rele vant upon a consideration of the equity of the double taxation to which profits so earned may be subjected, but it does not, it is submitted, cast any doubt upon the legality of the practice.” 12 * Compare The Gramophone and Typewriter, Ltd. v. ...

Thomson explained part of this purpose that the appellant should dispose of its members’ surplus horses as advantageously as possible for them but the disposal of them was the main consideration. ...

As described by Justice Noël in Brar, the appeal is “robust.” [63] I acknowledge that |||||||||| ’s Charter and constitutional arguments deserve consideration and note that similar issues have been raised before this Court in other proceedings. ...

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. ...

I will therefore analyze the Appellant’s circumstances with the foregoing considerations in mind. ...