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Huet because, according to him, it was considered that he was already making enough money with the Software. ... As a result of these elections, the excess dividends are considered taxable dividends, and the result is the authorized avoidance of Part III tax. ... However, the valid elections made pursuant to subsection 184(3) authorize the appellant to avoid this tax, with the excess capital dividends being considered a taxable dividend. ...

However, where the nature of a taxpayer’s activities contains elements that suggest that the activities could be considered a hobby or other personal pursuit, the venture will be considered a source of business income for the purposes of the Act if it is undertaken in a sufficiently commercial manner [9]. ... The Court must therefore consider whether the Appellant was carrying on this activity in a sufficiently commercial manner so as to be considered a source of business income. [42] At paragraph 54 of Stewart [10], the Supreme Court stated: [54] … in order for an activity to be classified commercial in nature, the taxpayer must have the subjective intention to profit, in addition, … this determination should be made by looking at a variety of objective factors … This requires the taxpayer to establish that his or her predominant intention is to make a profit from the activity and that the activity has been carried out in accordance with objective standards of businesslike behaviour. [Emphasis added] [43] The “reasonable expectation of profit,” which was the test prior to Stewart [11], must, of course, be considered if there is some personal or hobby element to the activity in question. ...

He considered these areas to be the least valuable portions of th property in any event. ... I do not believe therefore that we can break down plaintiff’s intentions into separate intentions with respect to different portions of the property and therefore conclude that since there was no firm intention of developing the portion sold in 1971 the gain in this sale must be considered to have resulted from an adventure in the nature of trade. If we consider the property purchased as a whole the intention to develop at least a major portion of it appears to be clear, and subsequent changes of plans cannot be considered to have retroactive effect even if they result in an alteration of the Original intention. ...

I accept Herman’s evidence that the building was acquired for the purpose of producing income, notwithstanding that it was demolished about 6 years later and that its demolition was one of the options considered (and rejected) when its purchase was under consideration. ... The valuation made by Davis was based largely on what he considered to be comparable sales, coupled with the municipal assessments on the land and building. ... These approaches are not infallible and they do not provide governing tests, but I think that they can be considered to be useful in looking to see whether $510,000 for the building is reasonable or manifestly or probably out of line. ...

In particular, it was agreed that products bottled in a container larger than 450 ml were considered to be destined for use by a beauty salon in its operations; products under the 450 ml size were considered to be sold at the retail level. 4 Following that agreement, Revenue Canada sent a communiqué to members of the Association informing them of the details of the arrangement, known as the Alternate Tax Accounting Method. ... Code 3700/83-1 By virtue of the information we have obtained from different sources and the minimal amount of documentation available, we have come to the conclusion that the clients have opted to pay the sales tax. 23 Following receipt of the Notice of Determination, Ninecan considered the explanation offered by the Deputy Minister of National Revenue. ... The Minister of National Revenue has considered the information and reasons set forth in your Notice of Objection and renders the following decision. ...

The more closely a taxpayer's business or occupation is related to real estate transactions, the more likely it is that the income will be considered business income rather than capital gain. ... First, which purchase should be considered: the one on December 4, 1987 entitled “offer to purchase”, or the one on February 11, 1988, which was the notarized agreement? 87 In Hill-Clark-Francis Ltd. (4.02(11)), the Exchequer Court held, affirmed by the Supreme Court of Canada, that it was not the intention on the date of the offer to purchase that had to be considered, but rather the intention on the date of the final contract. ...

The status of the property held in trust by the executors under the will in question must, of necessity, be considered in the present matter, since it has been resorted to to pay the succession duties. ... It is, however, not merely the interpretation of the language of Section 31 that is to be considered but the subjectmatter to which it applies. ... Gibsone, J., who considered that the duty payable in respect of these interests should be computed from year to year and paid by the trustees when the amount of the annual revenue was determined, gave judgment for the full amount of $83,983.03. ...

His conduct must be considered as that of the persons for whom he acted from time to time. ... He was holding it for a rise in value and resale at a price which he considered really profitable. ... Several timber licences were offered to him and he considered some of them. ...

Lalonde’s eligible income, one can see that the officer considered the information provided by the applicant. ... Lalonde with her initial application, reviewed the first officer’s notes, and considered Ms. ... If no contract, the income from a family member may be considered a “gift”. ...

Similarly, the Applicants submit that the Minister should have considered the broader impact of Mr. ... By referencing consideration of “other circumstances,” the Minister demonstrated that her consideration went beyond what the current Guidelines provide. [41] The Minister considered Mr. ... He fired CFOs and CEO and took measures to resolve the situation:- personal line of credit, personal mortgage on his house, agreed to payments plan with CRA, close non-profitable divisions, sold assets, reduced staff. [62] While the CRA considered Mr. ...