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She also noted that Form T3012A is not necessary to withdraw the excess amount and any delays that result from having the withdrawal approved are not considered to be a reasonable error. [11] A CRA Resource Officer subsequently endorsed the Report and issued the Decision on behalf of the Minister, denying the Second Request. ... Both the outcome of the decision and its reasoning process must be considered in assessing whether these hallmarks are met (Vavilov at paras 15, 95, 136). [16] Such a review must include a rigorous evaluation of administrative decisions. ... As a result, the taxpayer’s innocence or lack of intent — which are subjective factors — are not determinative of the reasonableness of the error, though they may be considered in the Minister’s analysis (Froehling at para 26, citing Lepiarczyk v Canada (Revenue Agency), 2008 FC 1022 at para 19). ...

Substantial documentary evidence was also submitted. [21]   The IAD considered Dr. ... However, the IAD found no evidence that the Applicant should be considered as disabled. ... There is no “rigid template” for the analysis but all relevant factors should be considered. ...

This convention holds that the business is considered to be able to carry out the transactions in question and honour its commitments [17] in the foreseeable future. ... That is why it is considered that the supplementary notes are an integral part of the financial statements. ...   [46]          Even if standard SOP81-1 is not in itself considered to be a standard approved by the official body in the United States, nonetheless, by adopting it, Bombardier was considered to have applied GAAP. ...

He asserted that it was only when it leaves the plant that it is considered by the appellant and its insurance company to be at the risk of the customer. ... Although several problems were disclosed the initial results were considered satisfactory. ... Since the expenditures were not in fact paid for by Bruinsma then or later (although charged to him), for the purposes of this subsection the appellant could properly be considered as having made those expenditures. ...

That proportion of 1.7 per cent was intended to represent not only the minimum amount of net revenue which would be considered as having been earned but also the maximum. 3. ... This does not mean, however, that the revenues themselves are not to be considered as reasonably attributable to an active business of the plaintiff carried on in Canada nor does it mean that some proportion of the revenues is to be excluded. ... Like all circumstantial evidence, unless supported by other evidence, it should not be considered as conclusive and must be disregarded when clearly contradicted by other direct or more reliable evidence. ...

  [5]   Saskferco described the offsetting transactions as a “natural hedge,” which is a term used to describe foreign currency receipts and expenses that, considered together, eliminate exposure to foreign currency fluctuations. ... The primary argument will be considered first.    Translation of revenues   [41]  For financial statement purposes, the appellant translated a portion of its U.S. dollar revenues at the rate of exchange in effect when the Notes were issued. ... Placer Dome Canada Ltd, 2006 D.T.C. 6532 (S.C.C.), which considered the meaning of “proceeds” from a mine for purposes of the Ontario Mining Tax Act.  ...

Accordingly the only question to be considered is whether the profit which was undoubtedly realized in the present matter is a profit from the business carried on by the appellant. ... C.].R. (1927), 13 T.C. at p. 1102 where he said that he had considered that it was a ease where they had some capital lying idle and they embarked upon an exchange speculation. ... To what extent they touch such eases arising’ under the income War Tax Act need not here be considered. ...

The facts to be considered are, however, not identical and the appeals must be considered separately. ... The company then appealed to the Income Tax Appeal Board and, in a considered judgment delivered by Mr. ... The matter is to be considered without reference to the amendment made to Section 127 by Section 31 of chapter 29 of the Statutes of 1952, by which the expression was defined. ...

James had intended that the payment be considered support amounts eligible for deduction. ...   [11]         There are several cases that have considered what is meant by payable on a periodic basis. ... The legal obligation, even if considered to be created currently, is an obligation to make good the periodic payments, but more on this later ...

IT 73-R6 states in part: … A corporation that operates a hotel is generally considered to be in the business of providing services and not in the business of renting real property. Accordingly, the business is normally considered to be an active business rather than a specified investment business. ... The term "principal purpose" was judicially considered in Mayon Investments Inc. et al. v. ...