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To determine if AIL’s business is being carried on from the fixed place of business, the following factors should be considered:  -                      use of premises by AIL-                      control by AIL over premises-                      legal right to exercise control over premises-                      degree to which premises identified with AIL business-                      who paid for expenses of premises-                      who paid for equipment used at premises-                      who made management decisions-                      what contracts were concluded from premises-                      what AIL products were kept on premises-                      did AIL have any Canadian employees-                      who bore the risk of the operation from premises-                      how many principals were represented by the agent-                      were agents subject to detailed instructions or comprehensive control [48]     Respondent’s counsel stressed the concept of integration, though apart from the case of Panther Oil, this does not appear to be a consideration, let alone a determinative factor. [49]     All agents work from a place, whether a PGA’s office or the agent’s home office, that meets the criteria of a place of business and one of permanence. ...

Whether a reasonable expectation of profit existed may be a factor that is taken into consideration in that analysis.   64                 The Minister and the courts below made much of the fact that the appellant anticipated a capital gain from the eventual sale of the properties.  ...

In a globalized world, practical reality, as well as political and economic considerations, will encourage countries to sign tax treaties. [12]            For example, whether a taxpayer can avail itself of a double taxation exception is a matter to be settled between the countries that have entered into a tax treaty. ...

The appellant made a commercial and business decision, after careful consideration, to enter into the swaps in order to protect its consolidated group equity. ...

Refusal to complete the transaction would appear to have been prompted by considerations other than difficulty in identifying the land agreed to be sold”. ...

           (9)      Summary [52]                           These considerations are sufficient to dispose of the appellants’ argument that a point-to-point transmission is necessarily a private transaction outside of the scope of the exclusive right to communicate to the public.  ...

"Reasonable" is a term encompassing both objective and subjective considerations; "expectation", means something more than mere "hope"-perhaps it is closer to "anticipation"; and "profit", is a calculation taking into account the Act and GAAP, with little need for subjectivity in my view.... ...

Persons must have confidence in government because, among other things, they rely on government. [75]         The consideration Revenu Québec gives to applications for GST registration numbers troubles me. ...

This defect has to do with the role that notaries and lawyers are expected to play in safeguarding their clients’ right to professional secrecy and the fact that they ultimately bear alone the burden of safeguarding that right when a requirement is issued. [54]                           Judicial consideration of a requirement under s. 231.7   of the ITA   is not automatic. ...

That case dealt with an assessment made under section 160 of the Income Tax Act, which renders a non-arm's length recipient of a gratuitous transfer of property from a delinquent taxpayer liable, jointly and severally with the transferor, for the transferor's tax liability, up to a limit defined as the lesser of the extent to which the value of the property transferred exceeds the value of any consideration that may have been given for it, and the total of all amounts each of which is an amount that the transferor is liable to pay under this Act in or in respect of the taxation year in which the property was transferred or any preceding taxation year. [11] It was the latter expression that applied in that case. ...