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The Tiger Cats were considered as a public trust belonging to every inhabitant of Hamilton. ... Such statements must be considered along with the objective facts. When the taxpayer is an individual the self-serving nature of such statements stands out. ... It is significant that the committee considered a number of different sites. ...

Ltd. despite the fact that it was a trading asset and had been considered as such by the old company; (g) After it had changed its name to N.T. ... We considered again that this was a public utility and there was every reason to believe that it should prove to be a conservative investment. ... To this extent that we considered eight dollars ($8) a share to be a proper price.” ...

As the Appellant’s counsel had pointed out in argument, only the use of these attributes can be considered the tax benefit for the purpose of this appeal. ... [30] Section 245(3) defines “avoidance transaction” as a transaction that results in a tax benefit, either by itself or as part of a series of transactions “unless the transaction may reasonably be considered to have been undertaken or arranged primarily for a bona fide purpose other than to obtain a tax benefit”. ... Halyk’s testimony that all options were considered and analysed before deciding on selecting Biomerge as the conversion candidate, it is clear from the testimony of Mark Kearl, the CFO, that he was instructed only to consider targets with tax loss attributes and only interviewed this type of candidate. (2) The notes of Mr. ...

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 combination of concerns, when the evidence is considered together, tends to indicate that on the whole the "arrangements" are not bona fide, this too should be fatal to the scheme. ... Even if offsetting entries could be considered payment, the Respondent argued that they would not be available here because Trafalgar Capital did not owe money to either ICON or to each partner. ... Furthermore, this provision has neither been judicially considered nor discussed in any depth by government commentary, or by legal scholars, authors or analysts. ...

[48] The parties do not dispute that the decisions are to be reviewed on the reasonableness standard as considered within the particular context in which the decisions were made. ... They assert that the projected rise in plastic pollution needs to be considered. ... There was no specific response to the breadth argument: I have fully and carefully considered the issues set out in your Notice of Objection. ...

McMuldroch, in consultation with their accountants and lawyers, considered off-shore planning and initially contemplated the creation of a Barbados tax‑exempt corporation. ... Lewinske testified that as an employee of APCI she always considered herself to be subordinate to both the Bambers and Mr.  ... Lewinske, who also considered Mr. Bamber to be one of her bosses while she worked for APCI during the taxation years in question. ...

Having considered all relevant information, I have decided to deny the appeal. ... Having considered all of the relevant information he had decided to deny the appeal.  ... The letter concludes: Having considered all relevant information, I have decided to deny the appeal.  ...

Both worked extremely hard in building up the business and for salaries which he considered were grossly inadequate. ... He considered that the benefit was justified to motivate them to continue to make the company prosper, and the company’s ability to easily overcome this loss was shown by its continued prosperity in the succeeding years. ... If it were to be considered as a dividend at all, and I do not so find, it would be more in the nature of a stock dividend dealt with in subparagraph 8(1)(c)(ii). ...

You have been considered to be a resident of Canada as of the date you applied for landed status. ... The applicant has always considered himself to be a resident of Canada for tax purposes. ... Much of this case has proceeded on the apprehension that once the applicant was considered a resident of Canada he could no longer be considered a resident of China. ...