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N-5 permitting federal offences to be prosecuted within the military justice system were considered. ... The Supreme Court considered the constitutionality of those circumstances in B010. ... For example, new evidence may substantiate an allegation of risk that was not previously considered. ...

Cameron stated that the TMTs were built to meet the demand for oil processing services. [11] [18]   On February 11, 2014, while Stark’s Notice of Objection was being considered by the CRA’s Appeals Division, Stark’s then counsel sent a letter [12] to the appeals officer who was considering the objection. ... Moreover, economic reality is such that the decision makers and actors who form the intention preceding a decision must deal with changing or constantly evolving realties dictated by the speed of technological developments and by the modern economy. [93] [76]   Justice Tardif also considered the meaning of the word “primarily,” as used in the phrase “to be used by him [i.e., the taxpayer] in Canada primarily for the purpose of.” ... At the hearing, counsel for the Crown stated that the CRA and she did not really see the available-for-use question as the primary issue. [110] When I raised the question during the hearing, counsel for Stark stated that it was the first time that it had been raised or considered by either side. [111] [93]   I have considered the dates stated in the respective income tax returns, as tabulated in paragraph 10 above, indicating when the various components of the Property became available for use, and I have also noted the testimony of Mr.  ...

In 2012 and 2013, ABL was one of TCIG’s top-performing subsidiaries and was considered to be the flagship subsidiary. ... Smoke may have considered TCIG and ABL, in a non-technical sense, to be a blended entity. [19]   When Mr. ... Smoke suggest that an additional factor to be considered in these Appeals is the relationship, if any, between the income of Mr. ...

In other words, an intermediary must be involved in every individual financial transaction otherwise it would not be “arranging for” a financial service. [32] Apart from Justice Hogan considering multiple factors in finding that Mac’s was not involved beyond providing space in its stores, whether Mac’s had to be involved does not appear to have been considered or discussed. [93]   In any event, a comparison of that case to the present case on the facts is distinguishable, in my view. ... The respondent is correct that some cases have considered authority to bind as a factor and I agree it could be a factor. ... However, I note that was but one of several factors the Court considered. ...

Now, is that considered a salary? It's a salary, I had to pay the guy a thousand dollars ($1,000) who had all the machinery, the electroset machine, it's very complicated to do the graphics. ... Cohen maintained that he was doing what he wanted and was given no orders by anyone, there were still certain points that should be considered. ... Cohen's ability that, in its prospectus I-5, Algo considered him one of the experienced executives in one of its subsidiaries and appointed him vice-president of the company (4.03.2(12)). ...

By virtue of it, the parties considered Outdoor Leisureland and Duha Printers to be con- trolled by the same person, Marr’s Leisureland. ... With such facts before an assessor it is not too difficult to appreciate the reason for the assessment and perhaps these facts may be considered again in another forum. ... Though the word “control” is not defined in the Income Tax Act, it has been considered many times in the jurisprudence. ...

Nor should it be seen as a general provision which must be considered overridden by “special” provisions which permit deductions in certain circumstances. ... On the facts of the case on appeal, however, there is no attribute of the transactions which gave rise to the respondents' attempted CEE deductions which could be considered a normal business practice. ... Generally, partnerships would not be considered persons, but the material before the Court suggests that it was Revenue Canada's consistent practice to treat partnerships as taxpayers: see, e.g. ...

Furthermore, a pleading will be considered frivolous if, assuming the facts to be true, it is plain and obvious that it cannot succeed (Canada v. Roitman, 2006 FCA 266, at para 15). [31] A pleading may be considered an abuse of the Court’s process when it is unfair to a party or would bring the administration of justice into disrepute (Toronto City v. ... Further, Schedule B, which details numerous “plans”, cannot be considered repetitive. ...

Finally, it could have purchased them from Madison and Vanac. [103] The first three options would all have resulted in an acquisition of control if the Madison Group, the Vanac Group and Delcor were considered a group of persons. ... To me, while the level of control that the Madison-Vanac Group had over the series of transactions is a factor to be considered, it is far less important than the level of control that the Madison-Vanac Group obtained as a result of the series of transactions. [175] There is no doubt that the Investment Agreement was an important factor in Deans Knight. ... There was nothing equivalent to the type of control obtained by the Madison-Vanac Group for the Court to consider. [178] Despite the foregoing, the control that the Madison-Vanac Group had over the series of transactions through the Syndicate Loan is certainly a factor to be considered. [179] Prior to the series of transactions, the Appellant was in a very difficult financial position. ...

Canada, [2002] 2 S.C.R. 645, where the nine justices of the Supreme Court considered the issue of reasonable expectation of profit from a business ... We would also emphasize that although the reasonable expectation of profit is a factor to be considered at this stage, it is not the only factor, nor is it conclusive. ... If the conditions are met, the Appellant must simply be considered a "specified member", thereby losing the right to the benefits claimed ...