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White- although the wording of s. 132.11(8) itself may imply that the legislative drafter considered that a return designation is included in the universe of transactions and events. ... If it contemplated, at the time of making the designation, that it would use some of the proceeds of such sale to fund a normal course issuer bid, it might be considered that such use of the proceeds was part of the same series of transactions that included the sale transaction. ...

Thus, it could be considered respecting a general partner that all of its purported contractual dealings with a partnership are legally to be treated as dealings with the partnership qua partner. ... Thus, it could be considered that a partner whose relevant transactions are not explicitly rendered taxable by s. 272.1(3) can access the exemption for financial services. ... Accordingly, even in 1995, the labelling of a distribution as salary would not necessarily cause the recipient to not be considered a partner. ...

S. 212.3(23) applies to deny the exemption from the application of s. 212.3(2) which otherwise would apply under s. 212.3(16) to an investment by a CRIC in a subject corporation where property received by that subject corporation from the CRIC as a result of the investment (or property substituted therefor) may reasonably be considered to have been used by it (directly or indirectly as part of a series of transactions or events that included the making of that investment) in a transaction (or event) to which s. 212.3(2) would have applied if the CRIC had entered into the transaction (or participated in the event) directly. ...

However, a special construction site of the employer generally will not be considered to be the place of business of the employer, so that costs of travel by the employee between his home and the construction site can potentially qualify for deduction (Martorelli). ...

Similarly, in Hogg amounts were considered to be received at the time of their vesting rather than when they subsequently were actually pocketed by the employee at the time of his retirement. ... The phrase "in respect of, in the course of, or by virtue of...employment" has also been considered in the context of s. 7(5). ... Even in the absence of s. 6(15), an employee generally would be considered to receive a benefit from employment, when an amount owing to his or her employer is forgiven, equal to the amount of the forgiveness (McIlhirgey, Bolton, Norris). ...

The Explanatory Notes of the Department of Finance state: In other words, this rule ensures that a member of an upper-tier partnership is also considered to be a member of a lower-tier partnership of which the upper-tier partnership is a member. ...

Expenses incurred with a view to potentially earning income from a business generally will be considered to applicable to that source even though, with the benefit of hindsight, they were unproductive (e.g., a loss from fraud, see Ruff). ...

Amounts received by a taxpayer will be considered to be "allowances" if their amounts are fixed or determined in advance, they do not correspond to the actual amount of expenses incurred personally by the taxpayer, and the taxpayer has no obligation to account for the amounts received (Verdon, Bériault, Rio, Côté, MacDonald). ...

Amounts may be considered to be "periodic" even though they are payable only during periods of illness or injury, their amounts depend on the most recent wage level of the employee and they may not be paid on time (Leonard). ...

Furthermore, even if a document is executed on or before the date in the document on which it is stipulated to be effective, there may be a subsequent amendment to the document- and the parties may wish the transaction to be considered to occur for tax purposes on the original effective date on the basis described in the amended document. ... There are exceptions to the rule that persons should not be considered to have effected a particular transaction in a specific way on a date if at that time they lacked the requisite intention to do so. ...