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The only question to determine is whether or not the defendant, in building a yacht for his personal use in the circumstances hereinabove set out, is to be considered a manufacturer or producer within the meaning of the Special War Revenue Act. ... The term, ‘manufacturing corporation,’ cannot, we think, be considered as comprehending the business of the defendant, if the words employed are interpreted according to the common understanding of such language. ... The Supreme Court however, affirming the judgment of the Exchequer Court in its conclusion, held that the bank, having a department where it printed all the stationery required for its banking operations, was to be considered, under subsec. ...

The words "‘travelling expenses” were also considered in the case of Ricketts v. ... I think it could not be said that the cost of board and lodging of a member of a Legislature or a member of the House of Commons, ete. while engaged over a period of many months in the performance of his duties, at a Provincial Capital, or at Ottawa, could, in any sense, be considered as travelling expenses and that is the governing word in the section. ... The clause was considered in the case of Minister of National Revenue v. ...

This assessment was in the following form: "I, James Joseph McCann, of the City of Ottawa, Minister of National Revenue for the Dominion of Canada, having considered audit reports made by Excise Tax Auditor N. ... Kennedy, and having considered the replies made by Frank H. Allison, Esq., on July 5th, 1948, and his solicitor, G. ... There is to be considered the question of the evidentiary value of the document purporting to be signed by the Minister of National Revenue, whereby the assessment of the defendant was made. ...

They considered that the entirety of the 33% of the income and not merely two-fifths of it was free from income tax for those two years and also for the year 1940 on the ground that no charging section applied to any of it until the year 1941. ... These they considered to be "‘unascertained persons’’ so that the wording of the subsection was precisely applicable. ... But ss. (4) of s. 11 remains to be considered. For the years 1938 and 1939 this subsection was in the following form: ‘‘Dividends received by an estate or trust and capitalized shall be taxable income of the estate or trust.’’ ...

Under the Excise Tax Act, the tax is payable on the closing date or the day on which ownership of the unit is legally transferred. [10] In the current appeal, the Respondent submits that “the particular time” when first use of the unit is to be considered is the day on which ownership of the Property was transferred to the Appellant: October 20, 2021. [11] The Respondent further reasons that the expectation of the Appellant on October 20, 2021, the date of title transfer, is the only time for consideration relevant in this appeal. ... The Appellant’s expectation with respect to first use in this appeal must be considered on the day on which tax became payable which is the “closing date” or the day on which legal title was transferred. The Appellant’s Position [13] The Appellant’s position is that it had a reasonable expectation that Tenant #1 would occupy the unit for at least one year and the “the particular time” when the Appellant’s reasonable expectation should be considered is when it entered into the lease with Tenant #1: December 30, 2020. [14] Based upon the Appellant’s testimony and documentation, Tenant #1 was employed as a nurse in Toronto and expressed no intention to leave the city. ...

Where the major addition is constructed as a extension to the existing house, the addition may qualify as the construction of a residential complex where both the existing house and the addition can essentially be viewed as a newly constructed residential complex or the existing house has been incorporated into the addition so as to essentially form a newly constructed residential complex The construction of a porch, sunroom, family room, bedroom over the construction of more than one room is not normally considered to be the construction of a single unit residential complex. ... Some of the factors that may be considered in determining whether the construction of a major addition is the construction of a residential complex are the ratio of newly constructed floor space to the existing floor space, the relative size of the new construction, the number and type of rooms of the new construction, the degree of annexation of the existing complex into the new construction, the type of changes that had to be made to both the exterior and interior of the building to accommodate the addition, the overall cost of the addition, the presence of new mechanical (e.g. plumbing and electrical) systems, etc. ... If renovations which are expressly provided for under the Act must be so substantial as to require virtually gutting all of a pre-existing premises to qualify for a rebate, additions, for which there are no express provisions in the Act, should (if they are to be considered at all) presumably be more substantial yet. ...

C.R. 174; [1962] C.T.C. 231, considered these authorities and others in application to the following circumstances: The taxpayer had, for many years, a contract with Doulton & Co. ... Limited as well considered to be the appellant’s interest in the goodwill and business in Doulton products in Canada. ... The net income of the mortgage department, before general and administration expenses are considered, ranged from 27.6% in 1958 to 51% in 1961 of the whole net income of the taxpayer’s business. ...

Would the note still be considered an absolute liability to repay $85,000?  ... The trial judge considered it important; the Federal Court of Appeal did not ... The “default” provisions cannot be considered to alter this contingency. ...

The Minister considered that this was a specified public interest within the meaning of section 36.1 of the Canada Evidence Act which position was accepted by the Honourable Chambers Judge. 18. ... Although the Minister was made aware of certain facts regarding the period of time prior and subsequent to the fair price determination period such facts were not considered relevant by the Minister. ... Whether it is improperly enlarged or not, will be further considered herein. ...

  [41]     In Tesco there were a variety of programs considered. In very general terms, customer loyalty reward points were issued for vouchers for future purchases. ...   [58]     The Respondent argues that the Points should be considered as a “coupon” as defined in section 181 of the Act. ... While other courts have considered the the former question, none to my knowledge have considered the latter question ...