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Chan considered that subsection 97(2) might be relevant to the ruling request. [55]            The next day Mr. ... Gouin-Toussaint that they considered this further consultation to be appropriate. ... Read's reference to a "position in society" was inappropriate and ill considered. ...

The function of this requirement is to remove from the ambit of the GAAR transactions or series of transactions that may reasonably be considered to have been undertaken or arranged primarily for a non-tax purpose.  ... For example, transactions that may reasonably be considered to have been undertaken or arranged primarily for family or investment purposes would be immune from the GAAR under s. 245(3).  ... The section is cast in terms of a double negative, stating that the GAAR does “not apply to a transaction where it may reasonably be considered that the transaction would not result directly or indirectly in a misuse... or an abuse”.   ...

Overall, he considered the 2012 budget reasonable. Mr. Michelin also noted that Deloitte considered it reasonable as well. ... Mady considered the figure to be at least within the realm of possibility. Deloitte, in doing the due diligence for DCC, considered the figure reasonable. ...

Overview [31]   The application of the GAAR to Partnerco will be considered first. ... The Tax Court was required to consider all three. [39]   The Court also considered the reasonable tax consequences for Partnerco if the GAAR were to apply. ... The Crown’s submissions will be considered first. (2)   Was there a tax benefit? ...

On the other, some decisions considered that the violation of section 18 of the Immigration Regulations, 1978, which is the equivalent of section 196 of the IRPR, did not automatically affect the general interest. [24] (ii) Line against the appellants’ position [62]   A series of Court decisions considered the interests protected by the IRPA to be of directive public order and that a contract of employment exercised by a foreign national without a valid work permit must be sanctioned by absolute nullity: Isidore v. ... But application of these principles has evolved over the years to meet changing needs and realities… Not all contracts which violate a law or regulation, however indirectly or theoretically, must be considered absolutely null. ... P‑40.1, is considered to be of protective economic public order as a whole in a number of decisions, such as: 9002‑5073 Québec Inc. v. ...

The alleged harm is already crystallized and can as such be considered imminent. ...   [120]   In addition, having considered the evidence presented by Mr. ... I also considered the question of justice and equity in agreeing to the interlocutory reliefs sought by Mr. ...

Other factors considered by the Provincial Treasurer were summarized by the defendant as follows. ... In so far as Dover Park was considered that was essentially the whole deal. ... The defendant concludes that the Provincial Treasurer made it clear in his direction letter that he considered the Alberta and Southern case and considered it not to be binding on his decision. ...

Choulli had developed in the Appellants’ case, and which would be considered by the GAAR Committee. ... The assertion that other analyses were not considered by the Minister’s auditors concerning the Appellants is possible, but not necessarily more likely than not. ... Situated as preamble overtures in the replies, frankly, features rather than diminishes such salvos. [149] The Respondent shall provide a description of the “strategies” and “opportunities” considered and a description by list of those ignored and irrelevant. ...

In fact, even in a technical interpretation letter dated November 14, 1985 (Exhibit A-3) the increase of income for tax purposes attributable to the credits does not appear to have been considered. ... Consequently, counsel for the appellant emphasized that the instant case should be considered in light of this statutory objective. ... "Safe income on hand" refers to that portion of the safe income of a share which can reasonably be considered to contribute to the capital gain on that share. ...

Thus any course by which such a serious consequence may be avoided must be carefully considered by our courts. ...