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Régent Blouin, counsel, wrote to the tax authorities on November 5, 2002, to inform them of the Appellant's position and state the reasons it considered the assessment to be incorrect; (add letter)   31.       ... Results   §         The amount of the advance received by Mary is not considered as employment income. ...  -          If the advances are more than the amount of the award, the difference is considered employment income. ...

The question then becomes whether the transaction(s) may reasonably be considered to have been undertaken or arranged primarily for a bona fide purpose other than to obtain a tax benefit ... The Appellant also argued that the Redemption is irrelevant to a determination of whether the 1993 Share Sale and First Amalgamation have bona fide non-tax purposes because the First Series of Transactions have to be considered alone in ascertaining whether the primary purpose was to achieve a tax benefit ... Canada, 2007 DTC 5172, 2007 FCA 113, the Federal Court of Appeal confirmed that the overall purpose of the series of transactions must be considered in understanding an abuse analysis. ...

Langdon, or any of their associates, would have considered it to have any value at all. ... It did not contain the words "may reasonably be considered that... ... Again, subsection (4) did not have to be considered. [61]          In OSFC Holdings Ltd. v. ...

For tax purposes, such remuneration is considered sourced where the training took place and should be allocated on the basis of working days. ... As a result, they are considered taxable to the extent the other services that you provide to Air Canada are performed in Canada. ... The only relevant factor to be considered is whether the remuneration is attributable to duties performed in Canada. ...

This disposition was considered to be a gift of property by the Appellant to the Class “B” shareholders. 5. ... Martin considered that the Class B common shares would not be subject to any material minority discount as of August 28, 1989. ... The same fact was not considered to be an important factor by Mr. Martin in establishing the value of the Class B common shares after the Special Resolution. ...

This project is considered as qualifying under section 2900(1) of the Income Tax Regulations. ... This project is therefore considered as qualifying under subsection 2900(1) of the Income Tax Regulations. ... Rompré indicated that he considered the findings of research conducted on an experimental farm in ideal conditions to be less convincing. ...

If the answer to the first question is yes, may the transaction, or transactions, reasonably be considered to have been undertaken or arranged primarily for bona fide purposes other than to obtain the tax benefit? ... It did not contain the words “may reasonably be considered that...” This Court, for purposes of decision, assumed, without finding, that the test was subjective. ... It simply purchased a partnership interest on what it considered to be, and ultimately proved to be, commercially advantageous terms. 4. ...

If only the interest payment transaction was considered and market rates and other considerations were ignored, a finding of undueness could never be made. ... In accordance with the Fording approach, all the circumstances must be considered to properly answer the question of artificiality. The Tax Court Judge considered the series of related transactions in this case to determine whether the interest deduction artificially reduced income. ...

The consortium which eventually formed AltaLink submitted what was considered the best offer. ... In this process, the potential recapture of the premium paid over the net regulated book value and the impacts on ratepayers were expressly considered. ... a performance-based regulation plan could possibly result in a sharing of benefits with customers that would enhance earnings; this was being considered by the Board at the time of the transaction; b.       ...

Luciani considered this to be evidence that the plaintiff expected those accounts to be paid. ... This is consonant with normal accounting procedures which require that in preparing financial statements all current information be considered. ... There is one last argument concerning the amount of the reserve claimed which should be considered. ...