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There were many reasons why the DFO weren't considered. Q.             ... There were many reasons why the DFO weren't considered. They were considered where the QMP records did not agree. ... In fact, she admitted not having considered the Appellant's submissions. ...

But all these elements have an effect on the price of the shares on the stock exchange, and no doubt they were fully considered by the purchasers of the stock at the then prevailing prices. ... In Johnson’s Asbestos Corp v MNR, [1966] Ex CR 212; [1965] CTC 165; 65 DTC 5089, Jackett, P considered the meaning of the phases or activities of mining preceding the delivery of ore to the pit head. ... By a notice of assessment dated August 2, 1969 the Minister considered the aggregate net value of the assets to the value of $3,771,008.03 to be Canadian assets and succession duties in the amount of $1,703,250.88 were claimed thereon. ...

Labow had considered that his contributions to the plan were an expenditure rather than an off-shore investment. ... Labow clearly considered the funds held in the hands of the Trustee in the Caribbean to be their funds. ...   [90]     This is all the more improbable when considered in the light of Mr.  ...

It is my view that the collective acts performed on the part of Revenue Canada must be considered. ... Sinclair considered the accused to be at least a suspect. At the same time that Mr. ... Thus that particular search must be considered on the basis of being a warrantless search. ...

The more closely a taxpayer's business or occupation is related to real estate transactions, the more likely it is that the income will be considered business income rather than capital gain.   ... This definition can cause an isolated transaction involving real estate to be considered a business transaction.  ... He first reviewed the case law which considered the definition of "business" and "adventure or concern in the nature of trade".  ...

The Tribunal considered actual imports and decided that, absent a price response by Canadian producers, these imports would, as a matter of certainty, have increased in number.                       ... But if the Board acts in good faith and its decision can be rationally supported on a construction which the relevant legislation may reasonably be considered to bear, then the Court will not intervene. ... I note that my colleague has not simply considered whether the Tribunal's interpretation of s. 42 of the Act is patently unreasonable.  ...

In a GAAR assessment the text is considered to see if it sheds light on what the provision was intended to do. [96]         With respect to the contextual analysis, “... not every other section of the Act will be relevant in understanding the context of the provision at issue. ... The GAAR will not apply to deny a tax benefit where it may reasonably be considered that the transactions were carried out in a manner consistent with the object, spirit or purpose of the provisions of the Act, as interpreted textually, contextually and purposively. ” [52] [178]    Since each of the avoidance transactions was part of a series of transactions, I must consider both the individual transactions and the series. ... In such a case, whether a transaction is abusive will only become apparent when it is considered in the context of the series of which it is a part and the overall result that is achieved (Lipson, at para. 34, per LeBel J.). [53] Subsection 97(2) [179]    I will first address subsection 97(2), which was used to avoid tax on the transfer of the Three Real Estate Properties to the First Level LPs and the Second Level LPs. [180]    The Respondent argued that the rollover of the Three Real Estate Properties as part of the Oxford Transactions was an abusive use of subsection 97(2) since the series of transactions resulted in little or no tax being paid in respect of the Three Real Estate Properties. ...

Fontaine’s employment could not be considered pensionable pursuant to paragraph 6(1)(a) of the CPP or insurable pursuant to paragraph 5(1)(a) of the Act. ... Fontaine considered himself to be working for Dynamex part‑time as of November 1, 2004. ... Fontaine not be considered as part of its personnel, that is, one of its employees ...

The bank considered that the passing of certified cheques and deposits was without risk to the bank since the bank was not exposed to any loss; there was no loan, he declared ...   [79]     It is not any kind of activity or undertaking that may be considered a business; there must be some commercial quality to the activity or undertaking for it to qualify as a business. ... In this appeal the Supreme Court of Canada considered the provisions of s. 245 of the Act which were not in force until after 1987. ...

Bill Hawkins sold him most of his gems. [75]     On April 12, 1996, he sent $15,000 to Solomon Investment Group because he considered the deal with Transpacific was still alive. ... When asked when he thought it would be considered reasonable for him to have stopped being involved in this attempted sale, he said when he decided to go no further. ... This Court can envision the situation in a defalcation case where the actions of the taxpayer could be considered to be unreasonable under section 67. ...