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The amounts thus received may easily be considered as remuneration from an office within the meaning of section 8 and subsection 248(1) of the Act. ... The question of when a debt is to be considered uncollectible is a matter of the taxpayer's own judgment as a prudent businessman. That determination is a subjective one that must be made by the creditor taxpayer in an honest and reasonable manner after having personally considered the relevant objective factors existing in the taxation year for which the bad debt is claimed (see Hogan v. ...

Nikal, [1996] 1 S.C.R. 1013, and was also considered by the Supreme Court in R. v. ... Finally, different kinds of costs mechanisms, like adverse costs immunity, should also be considered. ...   [13]          Most recently, the Supreme Court of Canada again considered the issue of advanced costs orders in R. v. ...

He considered Laura Manor as his parents’ home. They had a large bedroom there and all their clothes were there. ... She described Laura Manor as a family-run business where the family members worked, and said that they considered it the family home. ... It was considered a summer place where they had barbecues; they also went there to do the regular upkeep. ...

  [26]          Iacobucci and Bastarache J.J. cautioned that the pursuit of profit test should only be considered when there is a personal element to the activity [5]. ... Reasonable expectation of profit is a factor to be considered at this stage, but it is not the only factor and it is not conclusive [6]. ... There is no evidence that she considered reducing her prices to meet changed circumstances. ...

Inc. considered to be interest. Ms. Dionne indicated to us the connections with the documents. ...     [23] Thus, the amount of the indemnity for contractual loss that will be considered here is not $431,000, but $423,000, because the Minister did not question the treatment of this amount in the reassessment ...   [54] In order for income to be considered a tax-exempt windfall, it cannot be income from a business or property within the meaning of subsection 9(1) of the Act, nor can it be income from a source contemplated in paragraph 3(a) ...

In Merrins, Justice Rip carefully considered the issues and rendered a decision that was subsequently upheld by the Federal Court of Appeal, [2003] 4 C.T.C. 259. ... All three of the appellant's sources of income are considered "Canadian benefits" and thus all are eligible for the election. [20]     When a section 217 election is made, certain important conditions apply. ... Deputy Attorney General of Canada Ottawa, Canada [1] S.C. 1966-1967, Part II, c. 75. [2] R.S.C. 1985 (5 th Supp.), c. 1. [3] OAS and CPP payments are considered "pension benefits" for the purposes of the Act. ...

Laperrière allegedly told her that the bill to the City was essentially considered to be electricity cost-sharing. ... Bédard considered that the School Board was entitled to an input tax credit of 100% of the tax paid. [1] Moreover, as to the GST paid on the balance of the amount billed by Hydro-Québec for the electricity consumption, Ms.  ... ”   [37]     Counsel for the Respondent points out that the assessment is in no way based on the supply of real property but rather on the supply of electricity whether or not it is considered to be a service. ...

(an) important factor to be considered is the proportion of the amount of space rented in relation to the total area of the building. ... Subsection 1100(14) in its entirety and IT-195R4 suggest that the words 'used... principally for the purpose...' are to be considered having regard to two approaches, one quantitative and the other qualitative. ... Where there is a relationship between the owner's business and the business carried on in the rented premises, the nature of the relationship between the businesses would have to be considered. ...

All things considered, counsel for the respondent took the view that the evidence shows that the T2201 form filled out by Ms.  ...   [20]     Paragraph 118.4(1)(c) sets out a list of activities that are considered basic activities of daily living in relation to an individual. ...   [21]     Finally, paragraph 118.4(1)(d) states that, for greater certainty, no other activity, including working, housekeeping or a social or recreational activity, shall be considered as a basic activity of daily living ...

He then considered the contributory value of the land and the existing building to be 20% of the total cost of the housing unit renovations. ... In calculating the FMV, the contributory value of both parts, the land and the existing building, must be considered. ...   [17]     In his second report, he made some adjustments to some of the fees associated with the part considered to be unrenovated and adjusted the value to $460,200 without changing his previous conclusion regarding the fair market value ...