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It is difficult if not impossible to say that where only value is being considered in which a variable inheres you can have any other than a fluctuating estimate. ... The power immediately to realize their value in money might have been considered as equivalent to possession of the money itself, though this would, it is true, have resulted in much difficulty in administration. ... Had the appeal before Potter, J., been limited to the question considered before the Income Tax Appeal Board, it should properly have failed. ...

If that be true, neither could be considered as within the ‘‘public use’’ provision. ... There remains to be considered the question as to whether or not school taxes are included in ‘‘municipal taxation” as that language is used in s. 4. ... There would appear to be no doubt that school taxes are by this legislation considered as but a part of the municipal taxes as a whole. ...

It was not in the financial interest of Great-West to fix the land valuation higher than what is considered to be the fair market value of the land. ... In my view, this is the basis on which the question should be considered. ... Should this, however, be considered as evidence of fair market value? ...

This determination is to be objectively considered, and must be based on all of the evidence available to the court.  ... To the extent a shareholder receives an amount less than or equal to the PUC it will be considered a non-taxable return of capital.  ... An amount returned to a shareholder on a share redemption may be considered a return of capital  rather than a deemed dividend under s. 84(3).  ...

However, if the organization’s primary purposes are charitable, then it must be considered (c) whether the other purposes pursued by the organization are ancillary or incidental to its primary purposes; and (d) whether the activities engaged in by the organization are sufficiently related to its purposes to be considered to be furthering them.  ... and (b) are the activities the organization engages in sufficiently related to its purposes to be considered to be furthering them?  ... Immigrants, considered generally, are not returning either to their native country or their spiritual home. ...

If it was properly to be considered revenue, the next task is to determine when it was to be included in income: entirely in the year received or amortized over the period of the lease of which it was the catalyst. ... Ct.), the Exchequer Court of Canada considered the tax treatment to be given to a subsidy received by the taxpayer from the federal government, pursuant to a statute, for the construction of a dry dock. ... Benaby Realties Ltd. (1967), [1968] S.C.R. 12 (S.C.C.), Judson J. considered the timing of recognition of certain proceeds of expropriation. ...

The Tax Court also characterized the gain as a capital gain:  [1997] 3 C.T.C. 2238.   7                                    The Court of Appeal reversed the Tax Court’s finding with respect to the interest deduction applying an “economic substance over form” doctrine which essentially dictated that the Borrowing Contract and Purchasing Contract be considered together:  [1998] 3 F.C. 64.   ... It is on that issue that the appellant sought and obtained leave to appeal in this Court.   8                                    The Court of Appeal did, however, agree with the Tax Court that the gain of US$21 million should be considered a capital gain.  ...

In a carefully considered judgment the learned Assistant Chairman of the Income Tax Appeal Board, Mr. ... On the evidence before him he held, however, that for the year 1946 $8,700 should be added to the amount of the assessment and a like amount deducted from that made in the year 1947; for the year 1948 he considered the amount as found by the Board should remain unchanged and, with these variations, dismissed the appeal. ...

Wachowich J. next considered the Agreement Letter.  He found that, under ss. 66   and 67   of the Financial Administration Act  , R.S.C., 1985, c. ... 4.Should a post-bankruptcy income tax refund be considered "wages" for the purposes of s. 68?   ... Parliament no doubt considered it unreasonable for the treatment of bankrupt persons to depend upon the happenstance of provincial residence.  ...

Appellant denied the claim for drawback and on an appeal from his decision to the Tariff Board only one question was considered, namely “whether or not the precipitators were ‘manufactured’ in Canada within the drawback items in issue”. ... In my view, this means only that “construction” was considered as the appropriate word to describe the process whereby furnaces and bridges are brought into existence, while “manufacture” was considered the appropriate word for precipitators. Any other view would result in precipitators of such size that they can be shipped whole being considered as manufactured objects and larger precipitators as not manufactured. ...