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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 ...

., who decided that the amounts paid by the appellant's clients for distribution to his employees should not be considered in calculating the amount of premiums payable by the appellant pursuant to the Act. ... The Court of Appeal then considered the meaning of "insurable earnings". ... The passages cited above clearly indicate that the Federal Court of Appeal considered that "it is section 66 which imposes the obligation to pay premiums and determines their amount", and that it was principally concerned with determining the meaning of "insurable earnings". ...

He considered the effect of the CUIA and concluded that since s. 20(2) provided that parties to an amalgamation can specify the manner of carrying the amalgamation into effect, it was open to the predecessors to agree that certain property would not become the property of Envision at the time of amalgamation. ... As a result, he held that s. 87   did not apply to this amalgamation. [18]                           Webb J. then considered the tax consequences of a non-qualifying amalgamation. ... Interpretations of that section suggest that the language ought to be considered as analogous to the provisions that this Court interpreted in Black and Decker: Manco Home Systems Ltd., Re, 1989 CanLII 2819 (B.C.S.C.). ...

Bruce also considered parking offered at the three Seneca College locations as reliable indicators of the value of parking at Branksome Hall. ... Walsh also considered parking offered at five residential apartment buildings in Rosedale, where the charges ranged between $85 and $105 per month. ... Bruce in his report where, at page 13 under the heading “Highest and Best Use”, he says:   For the purposes of this report, the existing use is the only use to be considered. ...

Tardif J.T.C.C. found that these sums were not research grants within the meaning of paragraph 56(1)(o) of the Income Tax Act (the Act) but instead should be considered a taxable benefit received during these years. ... The dispute originates in the fact that the Minister found that expenses of $2,731 for 1994 and $5,084 for 1995 could not be considered eligible expenses under subparagraph 56(1)(o)(i) because they constituted personal or living expenses. ... Well, that can't be considered as being, in my view, so much... it's rather an exploratory plan to go and verify, to see if those techniques might be importable or if he could do that. ...

In other words, even if the Class D shares, considered individually, had minimal value, they had a significant dilution power, thereby conferring a negligible value on the Class A shares. ... A consistent interpretation of this definition is that parties should always be considered to be at arm's length, i.e. at the creation of the relationship through the issuance of shares, during the period that the parties hold shares in 3320516 and at the end of the relationship when one party wishes to sell its shares in 3320516. ...   [29]      My conclusion that the non arm's length electricity contract between Deer  Lake and Corner Brook should not be considered in determining the fmv of the Deer Lake shares is not a conclusion of law nor is it based particularly on expert opinions. ...

Heier considered the wells as being technical successes despite the fact that there was no commercial production of oil and gas. ... Ringdahl considered that his work of looking at and interpreting seismic data constituted exploration work. ...   [83]         The role played by Compton Petroleum Corporation was considered by the Crown to be an element of a sham because Compton Petroleum Corporation had royalty-free access to the Seismic Data and carried on exploration activities without disclosing the 50% interest of the Joint Venture in those activities ...

Firstly, a loan by Redpath to T & L was considered; it was discarded due to possible obstacles which might be raised by the British currency control authorities in case a loan recall on short notice should be needed and exercised by Redpath and also due to the uncertain situation of the currency, the English pound undergoing fluctuations and presenting dangers of devaluation. ... We must emphasize that at all times, Redpath management considered Albion as an extension of itself. ... As we have seen, how- ever, it may have been done and where, other than from a situs in Bermuda, is an irrelevant matter to be considered; (B) a camouflage used by respondents, through a letter of instructions from Mr Dennis, purchasing manager of Redpath, in Montreal, to a nominal representative of Albion, in Bermuda, outlining documents to be signed, kept or returned, by way of offer, acceptance and confirmation, all documents which in the eyes of the prosecution demonstrate that Albion was a pure puppet, without any proper self identity, and reflecting indications that what Albion did in every respect, was what the respondents decided and did, the former being only a shadow moving along as the respondents moved. ...

Had he considered Mr. Cole’s evidence, as he was bound to, he would necessarily have concluded, in my view, that the appellant had made a prima facie case “demolishing” the Minister’s assumptions. ... Cole’s evidence was capable of “demolishing” the Minister’s assumptions and that had the Associate Chief Justice considered Mr. ...   [73]            I have carefully considered this Court’s decision in Njenga and the Tax Court’s decisions in Scragg and Redrupp and find nothing in those decisions to support the Associate Chief Justice’s view that oral evidence, on its own, cannot suffice to establish what it is intended to establish ...