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This argument is undermined by the explanations from the Minister of National Revenue [Minister] according to which the Minister’s Representative considered that Mr. ... Bertone’s advanced age (in his eighties) and functional illiteracy had been considered, but that his age was not the cause of his breach of his tax obligations more than 12 years previously and his illiteracy had been considered in the period mentioned above. [13] However, the Minister’s Representative upheld the penalties for late filing, since she was of the opinion that, despite Mr. ... Pietrantonio in his income tax returns for the years 2007 to 2009, which confirmed that the CRA had not considered these situations to ones of embezzlement or misrepresentation. ...

If not, the evidence need not be considered. Relevance: Is the evidence relevant to the PRRA application, in the sense that it is capable of proving or disproving a fact that is relevant to the claim for protection? ... If not, the evidence need not be considered. (b)   If the evidence is capable of proving an event that occurred or circumstances that arose after the RPD hearing, then the evidence must be considered (unless it is rejected because it is not credible, not relevant, not new or not material). ... This element of risk was not considered in the PRRA officer’s decision (the Court refers to uncontradicted evidence from the Archdiocese of Montréal, in a letter dated February 27, 2008). ...

where the amount can reasonably be considered to have been received                  (iii) as an inducement,...              ... (viii) may not reasonably be considered to be a payment made in respect of the acquisition by the payor or the public authority of an interest in the taxpayer, his business or his property;... 2      Canada Tax Words, Phrases & Rules, Dictionnaire Fiscal Canadien, Carswell Thomson Professional Publishing, June 1996, pp. ...

Cases considered by Margeson T.C.J.: Dundas v. Minister of National Revenue, (sub nom. ... The issue of the amount being a capital item was not considered in that case. ... This case is appropriate when considered in the context of section 7. ...

There, Le Dain J. considered whether provincial court judges were independent.  ... Having set forth these principles, Beetz J. considered the subject of the appeal.  ... Such an alternative "remedy" cannot be considered "adequate".  ...

His practice also included property acquisitions in depressed real estate markets where he considered that the markets would eventually recover. ... Cassils was attracted to the Shopping Centre investment based on the projected returns, which he considered quite attractive. ... Poole was offered a 10 percent share, although he was interested in a larger investment since he considered 10 percent to be a minimal investment. ...

The appropriate principles to be considered in interpreting taxation legislation were clearly set out in Friesen v. ... Cases Which Have Considered the Nature of a General Assignment of Book Debts   XXIII.          ... Yet ordinarily, in the world of commerce, a GABD is considered to be a security interest.  ...

Iacobucci J. made it clear that external documents, other than the share register of the corporation, the articles of incorporation and unanimous shareholder agreements, generally should not be considered in assessing de jure control (paragraph 85). ... [Emphasis added.] [51]   Thus, the Federal Court of Appeal reiterated that the factors to be considered must arise from one or more legally binding agreements, again confirming that the criterion for analyzing control in fact is narrow. ... Various family and economic factors could therefore be considered, provided that these influence only the composition of the board of directors.” ...

Cases Cited   Considered:   McClurg v. Canada, [1990] 3 S.C.R. 1020, aff’g [1988] 2 F.C. 356; distinguished:   Winter v. ... Consequently, as a general rule, a dividend payment cannot reasonably be considered a benefit diverted from a taxpayer to a third party within the contemplation of s. 56(2).  ... That cannot legitimately be considered as within the parameters of the legislative intent of s. 56(2).  ...

He accordingly considered that ss. 8 and 24.1 of the Quebec Charter have no application to the facts of the case at bar.                      ... However, the validity of this fourth paragraph in light of s. 24.1 of the Quebec Charter will have to be considered.                      ... It cannot be considered a " fouille " (search of a person), since the powers of access to work premises contemplate a physical place.  ...