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Dirk is considered to have held insurable employment during the Relevant Period while working for both the Payer and BV. ... Therefore, this criteria was met since the worker is considered ordinarily resident of Canada. ... Also, it does not appear that the “work or report condition” was formally considered. ...

.: Rule 147(3) provides the factors to be considered in exercising the Court’s discretionary power. ... Justice Rothstein stated that these other factors provided guidance as to the type of matters that might be considered relevant in Rule 57.01(i).  At paragraph 24 of his Reasons, Justice Rothstein discussed what should be considered appropriate under Rule 57.01(1)(i): 24.  ...

However, where the activity could be considered a personal pursuit, then one must ask if the activity is being carried on in a sufficiently commercial manner so as to be a source of income. 19. ... Boles considered showing her dogs and horses a hobby during this time. ... What I considered, what I wanted for my own law practice which was tight monthly financial reporting. ...

“Reasonably be considered” by whom? [53]            The respondent argued that the definition of tax shelter that was applicable to the taxation years in issue in this appeal was further problematic in that it provided no indication as to how the reasonableness requirement of that definition was to be dealt with by the Court. ...   [55]            The respondent also raised the question as to whether the statements or representations that were made could reasonably be considered to have led to the inference or conclusion that the mathematical component of the definition of tax shelter had been met. ... It follows, in my view, that the statements in the Tax Opinion that indicated that the acquisition cost of TIP licences would be deductible to prospective investors over a two year period can reasonably be considered to have lead to the conclusion that the mathematical component of the definition of tax shelter would have been met in relation to prospective purchases of TIP licences by prospective purchasers.   ...

., 90 D.T.C. 6312 (F.C.A.).   23                                Halliburton and Nowsco considered the form of contract entered into between the taxpayer and customer to be irrelevant.  ... In these and similar circumstances, the product is considered to be sold at the time the completed structure is sold and therefore such activities will qualify.  ...

The determination invokes reasonableness, suggesting that the possibility of different interpretations of the events must be objectively considered. ... Desmarais transferred only 41 of his shares of Comsercom, amounting to 9.78% of this company's shares, cannot be considered to have been concluded primarily for bona fide purposes, other than non-tax purposes. ... The specific anti-avoidance measure in former subsection 247(1) was no longer considered necessary because of the broad scope of the general anti-avoidance provision. [...] ...

The Minister did not reassess under subparagraph 152(4)(a)(ii). [38] This Court and the Federal Court of Appeal considered a similar issue in Kubbernus. [35] In Kubbernus the issue was whether a reassessment was issued under subsection 152(4.2) or paragraph 152(4)(b)(i). ... I have considered the Appellant’s arguments but they do not affect the outcome in this motion. [60] The starting point, which the Appellant acknowledges, is that he is a resident of Canada for purposes of the ITA. ... Therefore, based on the “Fruit of the Poison Tree” doctrine2, all correspondent signed by Mr Pace on behalf of The Respondent must be “Null” in full, and not be considered in any way in this case. ...

It also considered some jurisprudence in this Court and in the Supreme Court of Canada to the effect a "vehicle must be a means of conveyance with wheels and used for the carriage of persons or goods". ... Finally, the Tribunal acknowledges the testimony of both experts, which assists the Tribunal in determining whether the Le Tro-porters should be considered "vehicles". ... Her Majesty The Queen, [2002] F.C.A. 453, Justice Rothstein considered subsection 68.1(1) of the Excise Tax Act providing for a rebate of excise tax paid on goods exported from Canada. ...

The Court of Appeal considered the issue of standing and found that appellants indeed had standing.   ... When determining the incidence of a tax, both the context within which the tax operates and its purpose should be considered.   ... Conlon, [1943] A.C. 550; considered:   City of Halifax v. Estate of J. ...

Sparrow Electric Corp., [1997] 1 S.C.R. 411; considered: First Vancouver Finance v. ... Considered: First Vancouver Finance v. M.N.R., 2002 SCC 49, [2002] 2 S.C.R. 720; Royal Bank of Canada v. ... What is clear is that s. 227(4.1) does not create a beneficial interest that can be considered a proprietary interest. ...