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He explained that the Program provided “additional leverage” for his charitable giving but would not have considered a bank loan for such a purpose. ... The Queen, 2018 TCC 66 (“ Markou TCC ”), Justice Paris also considered a leveraged donation program. ... All of the Appellants indicated that they understood this. [148] It was also clear from their testimony, that the Appellants would not have considered applying for a loan from a conventional lending institution for the purpose of making a donation. ...

  [212]      This point was considered by the Federal Court of Appeal in Hammill v. ... It is an economically relevant fact that should have been considered by Mr.  ... CASES CONSIDERED   Canadian cases   Apa v. The Queen, 2004 DTC 2365 (TCC).   ...

First, s. 111(5) should be considered against the foundational principles of the Income Tax Act  . ...   [28]                          First, Paris J. considered the object, spirit and purpose of ss. 111(1)(a), 111(5) and 256(8). ... Background to the General Anti-Avoidance Rule [40]                          The present appeal is not the first time this Court has considered the GAAR  . ...

This factor has also been considered in subsequent investment income cases:  see, e.g., Lewin v. ... While it is true that the contract in this case was signed on the reserve, this factor cannot be considered significant, since the debtor’s place of residence was also on the reserve ... The judgment of the Court was delivered by Linden J.A. who analyzed the connecting factors considered in Williams.  ...

Dancers considered for lead roles generally are so advised when they are offered an engagement for the season. ... On that basis, Desjardins J.A. considered it appropriate to apply to Mr. ... She concluded that those factors, considered in the context of the special nature of Mr. ...

However, where the nature of a taxpayer’s venture contains elements which suggest that it could be considered a hobby or other personal pursuit, the venture will be considered a source of income only if it is undertaken in a sufficiently commercial manner.  ... Reasonable expectation of profit is no more than a single factor, among others, to be considered at this stage.   ... We would also emphasize that although the reasonable expectation of profit is a factor to be considered at this stage, it is not the only factor, nor is it conclusive.  ...

However, it is far from certain that a partnership can always be considered as operating a business within the narrower sense of the Act. ... It must be borne in mind that a partnership is not considered as having separate legal personality either in common law or in civil law. ... I have also considered the decision by my colleague Judge Bowman in Allen v. ...

., speaking for the dissenting minority, held the view (but with some hesitation) that the intention of the taxpayer should be considered the deciding factor. ... The nature of the transaction will play an important part in determining whether an amount may be considered as a capital or income receipt. ... The Crown stated in open Court that it considered the evidence of Larue as being frank and honest. ...

Weatherby considered that these two tracts of land had a per acre similar value. ... Weatherby's report was considered by him to be the upper limit of value benchmark. ... The sales that the latter considered extended over a ten-year period, from 1965 to 1976. ...

Hejazi’s evidence after I have considered the evidence of the Respondent’s expert ... McCann then considered private market sales by the Appellant and her spouse. ... McCann considered certain jurisprudence relating to the valuation of shares ...