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branches of these industries, and to manufacture and deal in such products and byproducts as may be considered by the Directors to be in the best interest of the Colony. ... The Articles of Association as well as the facts properly considered show that the Colony was set up both for a religious purpose and the object of operating a communal farm. In respect of the agricultural operations, the Colony cannot be considered otherwise than as a secular undertaking, it is not a charitable undertaking. ...

He pointed to the level of trading activity within his own RRSP as evidence that he carried on such a business outside his RRSP. [26] [32] In concluding that the appellant’s loss was on capital account, this Court held that the level of trading activity within an RRSP cannot be considered in determining whether a taxpayer was in the business of trading outside his RRSP. ... When considered in light of the overall structure of the TFSA rules, the purpose of the exception in subsection 146.2(6) — which makes income from the carrying on of one or more businesses by a TFSA taxable — is to ensure that the tax exemption is restricted to the passive holding of qualified investments. ... There is no indication that the Court considered paragraph 146(4)(b) — which expressly contemplates an RRSP trust carrying on business trading in qualified investments — and the Crown did not bring that provision to the Court’s attention. ...

Neither BDI nor Peninsula was looking to make money on the Tremont Apartments project since they considered it a cost of developing the condominium project. 8 Mr. ... At one time he considered that it may be necessary to “roll in a nominal asset to achieve this goal”. ... Gouveia stated that “maybe for a fleeting moment” the Canadians considered retaining the condominium development. ...

Certainly, they were not of the kind that would be considered as investments by a prudent person who was primarily concerned with securing a fair return on his money. ... Consequently, I do not see how it could reasonably be considered that their profits were merely enhancements of value of securities in which they had invested. ... And in view of the conclusion that I have reached it is not necessary to consider whether such profits could be considered as Income from property. ...

It is, however, quite a different situation when situs of shares is being considered for purposes of provincial legislative jurisdiction to levy estates tax or succession duties. ... In this respect the meaning of the expressions used both in Section 10(1) (c) and in Article V are thus narrower than that of the statutory provision considered in M.N.R. v. ... The precise kind of trading to a British port, which exposed a foreign shipowner to British taxation, need not be considered here. ...

I will simply add for the record that the final (stage two) factor to be considered in determining whether to exercise my discretion to address the China JG is not relevant. ... It then explains why it considered that the claimant in question faced serious restrictions on the practice of her religion. ... Among other things, it was considered that this would reduce the need to address issues related to credibility, and thereby reduce the length of hearing time as well as the time spent writing or rendering oral reasons. [218]   Accordingly, the Committee searched for and considered several finalized RAD decisions addressing the availability of IFAs in Nigeria. ...

For example, a specific admixture may be considered at the start of the project to meet a certain standard. ... A fine‑tuning activity will not be considered an SR&ED activity if its goal is not to advance technological knowledge. ... The lasting improvement of a property is normally considered to entail a capital expenditure. ...

It did not, however, abandon its plans for once it had decided to enter the Bermuda market, for whatever reason, it implemented that plan in a thoroughly businesslike and well considered manner. ... [sic] of Bermuda who said that for the purposes of Bermuda statutory law the activities of the plaintiff through its agent would be considered to be carrying on the insurance business in Bermuda. ... Indeed it reported all of the funds received from L.D.S. as income and all of the expenses, which it considered as deductible expenses, as expenses. ...

That expense was disallowed only because the Crown considered Dynamic to be carrying on a personal services business. ... The expression “more than” is used over 200 times in the Act and has been considered by this Court on several occasions. ... I am of the view that his comments in regard to part-time employees can be considered obiter ...

The evidence must be considered in relation to the test established by subsection 225.2(2) itself and by relevant cases, that is, whether on a balance of probability the evidence leads to the conclusion that it is more likely than not that collection would be jeopardized by delay. ... By agreement between the two principals in October 1986 Brough was considered to have purchased the assets of the company, though apparently no corporate documents were executed as evidence of the intended transaction. ... In the spring of 1987 the company left premises in Milton, Ontario where it had previously based its satellite dish operations, and withdrew to an address in Hillsburgh, Ontario where Manchee and Brough had lived and where they considered some of their business activities had been based. ...