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Income Tax Regulations, C.R.C. c. 945: 2900(4) For the purposes of the definition qualified expenditure in subsection 127(9) of the Act, the prescribed proxy amount of a taxpayer for a taxation year, in respect of a business, in respect of which the taxpayer elects under clause 37(8)(a)(ii)(B) of the Act is 65% of the total of all amounts each of which is that portion of the amount incurred in the year by the taxpayer in respect of salary or wages of an employee of the taxpayer who is directly engaged in scientific research and experimental development carried on in Canada that can reasonably be considered to relate to the scientific research and experimental development having regard to the time spent by the employee on the scientific research and experimental development. ... Pursuant to this provision, the following expenditures are SR&ED expenditures: 1- An expenditure of a current nature for, and all or substantially all of which was attributable to, the lease of premises, facilities or equipment for the prosecution of scientific research and experimental development in Canada, other than an expenditure in respect of general purpose office equipment or furniture; 2- An expenditure in respect of the prosecution of scientific research and experimental development in Canada directly undertaken on behalf of the taxpayer; 3- An expenditure described in subclause (A)(III), other than an expenditure in respect of general purpose office equipment or furniture; 4- That portion of an expenditure made in respect of an expense incurred in the year for salary or wages of an employee who is directly engaged in scientific research and experimental development in Canada that can reasonably be considered to relate to such work having regard to the time spent by the employee thereon, and, for this purpose, where that portion is all or substantially all of the expenditure, that portion shall be deemed to be the amount of the expenditure; 5- The cost of materials consumed in the prosecution of scientific research and experimental development in Canada; or 6- ½ of any other expenditure of a current nature in respect of the lease of premises, facilities or equipment used primarily for the prosecution of scientific research and experimental development in Canada, other than an expenditure in respect of general purpose office equipment or furniture. [22] [37] Because this Court found that the work related to the design and installation of the hydrodynamic system in the triplex does not constitute SR&ED, the first condition to enable the expenditures incurred by Hydro LMR for this work to be deductible in the computation of its income has not been satisfied. ... In the period at issue, the prescribed proxy amount was 65% of the amounts incurred in the year by the taxpayer in respect of salary or wages of an employee of the taxpayer who is directly engaged in SR&ED carried on in Canada that can reasonably be considered to relate to the SR&ED. [40] Therefore, where this Court finds that a taxpayer’s expenditures were not incurred for SR&ED, the taxpayer is not entitled to an ITC for those expenditures. ...

Consequently, she considered that the cost [6] of all of her shares [7] in the family business was $1,000,000. ... Gendron’s use of the capital gains exemption could be considered a direct or indirect tax benefit for Mr.  ... The analysis of whether this is an avoidance transaction would not change if I considered them as transactions. ...

While working as a psychic, he considered himself to have been an independent contractor. ... He took a training course in reading Tarot cards but considered his own clairvoyance to be an inherent gift. ... She always considered it necessary to obtain the permission of the Pilot in order to leave during a shift. ...

When the case came before the Federal Court of Appeal, the Court considered and denied the appeal on the merits. ... Standard of Review [79]            In the event that the Program and its recourse mechanism should be considered reviewable in the manner urged upon me by the Applicant, the applicable standard of review needs to be considered. ... Procedural fairness requires a meaningful opportunity to present relevant facts and to have one's position fully and fairly considered by the decision-maker. ...

Leyton, indicating more than $100,000.00 was then considered outstanding for taxes, penalties and interest. ... That company is not a party in this action and no claim on its behalf is here considered. ... There was no evidence that she was so considered or was so treated. [109]      No basis for finding a violation of equality rights assured to Ms. ...

These are exceptions, and it seems to me, that the notice to the tax-payer is so essential an element in the imposition of a valid tax that its omission ought to be considered quite as fatal as where there is no jurisdiction to tax at all. ... It was argued before us, though not in the court below, that this action of replevin would not lie against the collector as the goods would be considered in custodiâ legis. ... I think the provision for the giving this notice cannot be considered merely directory. ...

Revenue Canada considered Mr. Finkle's conduct as a serious matter and dealt with it. ... In so concluding, he considered the factors identified by the Supreme Court of Canada in R. v. ... The factors which are to be considered and balanced have been listed by many courts in the country... ...

These findings are not in dispute. [51] The Tax Court then considered whether the relevant transactions were an abuse. ... The Tax Court’s decision is to be reviewed on the palpable and overriding error standard of review, unless the issue involves an extricable question of law. [95] The Tax Court considered whether there was an abuse of subsection 111(5) of the Act, by itself, and also whether there was an abuse of subsection 256(8) of the Act together with subsection 111(5). ... These circumstances: reflect the intention that a dilution of control, or a loss of control by a person or group of persons to an undefined group, will not be considered offensive except in certain contexts, such as an amalgamation or a reverse takeover. ...

Leyton, indicating more than $100,000.00 was then considered outstanding for taxes, penalties and interest. ... That company is not a party in this action and no claim on its behalf is here considered. ... There was no evidence that she was so considered or was so treated. No basis for finding a violation of equality rights assured to Ms. ...

There is nothing to indicate therein that in reaching the value of the capital stock for taxation purposes the amount of any unimpaired accumulated profits was considered at all. ... Sharp, presently Assistant Chief Auditor, thought that these notations were made by him at the time the assessment revisions of 1937 were being considered, which, of course, is quite possible. ... Breadner had considered the same and had directed that it was to enter into the computation of the Company’s net profits, for taxation purposes, in the period in question. ...