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., considered the status of workers supplying services to a non-profit organization funded mainly by the federal government. ... Considering, however, the fact that the integration factor is to be considered from the perspective of the employee, it is clear that this integration was an incomplete one. ...   [21]      In his brief judgment- also concurring in the result- Noël, J.A. considered the matter of intention of the parties and his reasons are reproduced below:     I too would allow the appeal. ...

She reviewed the matter and decided his employment was excepted employment pursuant to the provisions of the Employment Insurance Act (the " Act ").She considered the factors set forth in paragraph 5(3)(b) of the Act. ... I say yet again because since its passage in 1990, several decisions of the Tax Court of Canada and several judgments of this Court have already considered what workable meaning could be given to subparagraph 3(2)(c)(ii). ... It is apparent from the evidence of Karen Bright- Rulings Officer- that she considered it extremely suspicious that Balraj Hothi would be laid off on December 31, 1998 due to lack of work and that the payor then hired the appellant- on January 4, 1999- to work in the same store. ...

However, the boiler replacement was an upgrade which constituted an outlay in capital, therefore, it was considered a capital expenditure and was not deductible. ... " [27] When an individual has done more than repair the defect but has created something different in kind then it is considered to be a capital expenditure. ... " [29] In regards to improvements that are considered different in kind, Earl v. ...

He considered the gross rent achievable for the properties multiplied by the number of units and deducted from that an allowance for bad rent and operating expenses for a typical year. ... He did not consider the equity value of the owner when he considered the mortgage amounts. [43] In cross-examination he admitted that he did not use the cost approach at all but he did admit that as the capitalization rate increases, the value decreases. ... In the case at bar there was rental income to be considered. Anyone buying the property would have taken the income into account. [63] The Appellant did not put forward the appraisals which he had done on the properties and there was no information forthcoming about them. ...

As a civil servant for the province of Quebec for over a decade she would have known that the way she was being paid was not consistent with her being considered an employee. ... In Wolf, job security was considered an indicia of employment. Both Décary J.A. at paragraph 120 and Noël J.A. at paragraph 123 make this observation. ... The Appellant stated at one point that she considered him a partner in the business. ...

Palladini considered that the appellant was employed as a travelling salesperson for Techno under a verbal agreement and that he was not an independent contractor. ... As noted in Royal Winnipeg Ballet at para. 64, the relevant factors must be considered “in the light of” the parties’ intent. ... This factor, which should be considered from the worker’s point of view, is not important and is not part of my analysis. ...

On first reflection this sort of income could realistically be considered either business income or property income. ... Judge Bowman considered that the owners provided tenants with far more services than is usually done in a residential apartment building. ... The appellants considered that they operated a business, not a rental property. ...

Palonek that in order for his disclosure to be considered complete, and thus to qualify for the VDP, Mr. ... Indeed, after this became an issue, counsel for the respondent confirmed that the documents in question were not in the material considered by Ms. ... This issue will be considered next. viii)       The Reasonableness of the Decision Under Review [121]        Counsel for the Agency candidly acknowledged that Ms. ...

In that regard, the Federal Court of Appeal considered, in Enseignes Imperial Signs Lt é e v. ... M.N.R., [1997] 3 F.C. 103 (C.A.), at pages 114 to 115, that "...for a good to be considered manufactured by an individual, it had to be given new form, qualities or properties by the activities of that individual". [32]       The jurisprudence pertaining to the definition of "manufacture" has therefore established that the manufacturing process may have more than one constituent part. ... C.R. 221, Cameron J. once again considered the extended definition of "manufacturer or producer". ...

The Respondent             The Minister Considered All Relevant Factors   [24]            The Respondent submits that the Minister considered all of the relevant factors and addressed all of the reasons and submissions submitted by the Applicant in respect of her second fairness request which is the Decision under review ... The Minister acted fairly and reasonably and considered all of the submissions made by the Applicant and all the relevant factors before him. ... The Minister reviewed and considered all of the information and submissions available to him and applied the Guidelines in the exercise of his discretion. ...