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However, by letter of September 10, 1986 the respondent rejected the application outright, on the basis that it could not be considered for the advancement of education in the charitable sense. ... An organization operated for primarily political purposes would not be considered charitable at law. ... I think the only proper way of approaching the question is on the basis that this head was in fact considered and was rejected although, in the circumstances, not expressly. ...

Paragraphs (c) and (d) authorize the deduction of interest payments which would not otherwise be deductible because they would be considered to be payments on account of capital prohibited by paragraph 18(1)(b). ... In paragraph 19 of IT-143R, for example, the following is stated: A provision such as paragraph 20(1)(e) that authorizes in qualified terms a deduction from income subject to certain exceptions is not always considered to have the effect of making the exceptions non-deductible for all purposes of the Act. ... The appellant’s third ground of attack must now be considered. It was appellant counsel’s contention, it will be recalled, that, in any event, the expenditure of funds to Pitfield was not made for the purpose of gaining or earning income. ...

I am going to rely on just a handful, as I believe they best reflect the factors Courts have considered in dealing with the single versus multiple supply issue. ... Conversely, when a number of elements of a supply are reasonably severable or separable, the supply will usually be considered as being a multiple supply. ... This situation is an example of the type of artificial transaction the Courts have ruled must be considered as a single supply. ...

Furthermore, the capital gain that would have been realized for the applicable period could reasonably be considered to be attributable to anything other than the income earned or realized by Plaza for that period. ... The share redemptions are not to be considered individually but taken as one at the conclusion of the series of transactions. ... The source of the gain is irrelevant, unless it could reasonably be considered to be attributable to income earned by any corporation between 1971 and the time that the transaction or series of transactions commence. ...

Earl Glick is a shareholder of the corporation and because of the interrelated shareholdings is considered not to deal with the corporation at arm's length. ... Therefore, the above benefit will be considered as a dividend, which will be subject to non-resident withholding tax. 11. ... If the dwelling was to be retained and noting the layout of the site and the location of the "Top of the Bank”, it is considered that a lot could have been severed in the southerly part of the site. ...

The definitions speak of receipt as well as payment to, and so both transactions are considered exempt supplies and hence all these activities are not considered a business that would qualify as a commercial activity of the Appellant and are activities that make up all or substantially all of the Appellant’s business activities. ... It has no other activities of any kind other than activities not considered commercial activities by definition. If it has no commercial activity, then the services it supplies cannot be considered taxable supplies by definition above ...

Indeed the auditor for Revenue Canada considered them such. Appellant’s counsel argued that this conclusion foreclosed the Minister’s argument that they were a return of consideration. ... According to paragraph 6202.1(1)(b) of the Regulations the transfer of property or conferral of a benefit must “reasonably” be considered a return of the consideration paid. ... Since I have considered the issue as directed by the Federal Court of Appeal and since the appellant is successful, it is not necessary at this time to consider counsel’s submission with respect to Continental Bank, supra. ...

I will repeat what I regard as the most relevant words of subsection 55(1): 55(1)... where the result of one or more sales,... or other transactions of any kind whatever is that a taxpayer has disposed of property under circumstances such that he may reasonably be considered to have artificially or unduly (a)... ... Therefore, the Appellant is brought within the opening words of paragraph 55(1)(b) in the sense that: the result of one or more transactions is that the Appellant has disposed of the common and Class A shares of Co. 908 under circumstances such that the Appellant may reasonably be considered to have created a loss from the disposition. [21] The critical question is whether the Appellant may reasonably be considered to have “artificially or unduly” created the loss. ... Central Supply Company (1972) Limited et al, 97 DTC 5295, the Federal Court of Appeal considered the application of subsection 245(1) to certain limited partnerships engaged in financing oil and gas explorations. ...

To formulate a decision then, the overall evidence must be considered taking into account those of the tests which may be applicable and giving to all the evidence the weight which the circumstances may dictate. ... " [38]          Counsel for M.P.I.C. has argued that driver education is not its main business and thus this work cannot be considered to be an integral part of its business. ... It asserts that between 1967 and 1995 M.P.I.C. considered the driving instructors to be employees and it made statutory deductions. ...

Nova Scotia (Attorney General) [10] the Nova Scotia Court of Appeal considered the entitlement of the appellant retailers to a rebate of tobacco tax paid. ... It is unequivocal in imposing the duty at the time of packaging; it leaves to the Governor in Council only the determination of the point in time at which the product is to be considered packaged. ...   [19]     Considered only textually, the expression “the general public” might be taken to mean everyone in North America, or everyone in Canada, or simply a large and diverse group of persons. ...