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Manley was considered to be a capable manager although Romantino felt that on occasion he spent too much time away from the office. ... The concept of vagueness was considered by Lord Denning in Fawcett Properties Ltd. v. ... The word principally” found in subsection 127(10.1) of the Act was considered in Yorkton Broadcasting Ltd. v. ...

The works being appraised will have to be considered a testament to a period or era rather than a simple value linked to market fluctuations.   ... A look at our history will show us the importance of religion in Quebec, which is actually considered the cradle of Catholic faith in America. ... Lastly, she explained that she considered the prices paid at the auctions only reflected the value of the design or sketch, and not the value associated with framing the works ...

Under the OECD model treaty and most tax treaties, a corporation is considered to be a national of the country under whose laws it derives its status. Therefore, tax provisions can be considered to discriminate on the basis of nationality where they treat corporations incorporated outside Canada less favourably than those incorporated in Canada. ... Therefore, only provisions that distinguish between corporations expressly on the basis of their place of incorporation can reasonably be considered to discriminate on the basis of nationality. ...

It is not realistic that the appellant should be considered in isolation. ... It was held that business activities need be neither extensive nor profitable in order for the taxpayer to be considered as carrying on an active business. ... In neither event could it be considered as carrying on an "active business". ...

Fraser can be considered as an expert and to testify as such. Although I am most impressed with Mr. ... Based on the above, Fraser considered the sales of four lots in the Forest Lawn area of St. ... Lee can be considered as an expert witness and is qualified to give evidence as such. ...

Counsel compared the situation to that which was considered by the Federal Court of Appeal in Water's Edge Village Estates (Phase II) Ltd. v. ... Instead, the subsequent amendment must be considered along with all other relevant materials to ascertain the object, spirit and purpose of the provision. ... Subsection 120.4(5) generally applies where a specified individual would be required to recognize trust income that can reasonably be considered to be attributable to a capital gain realized on the disposition of shares of a private corporation to a person with whom the specified individual does not deal at arms length. ...

Where possible, BCF directly attributed what it considered to be single-use inputs to either exempt or taxable supplies. ... Brown, at paragraphs 22 and 23: [22]      One factor to be considered is whether or not the alleged separate supply can be realistically omitted from the overall supply. ... Based on the facts, BCF’s categorization of the infrastructure decks as common cannot be considered unfair or unreasonable. ...

I am satisfied that the transaction cannot and should not be considered an involuntary disposition as the evidence indicates some negotiation taking place. ... It lists a number of factors which the courts have considered in determining whether a profit from a real estate transaction is income or capital. ... That is, if a taxpayer's regular business is associated with dealing in land, it will be considered that a sale of real estate is within his business. ...

The question to be answered is not whether the business activity is normally considered in the commercial mainstream nor whether it is traditionally Indian, but whether it is property situated on a reserve. ... In essence, in those cases, the judges considered what the relevant factors were and analysed them to give the respective factors the weight they thought it deserved. ... Is it because the clearing of trees and brush are not considered traditionally an Indian activity or are not integral to life on the Reserve in this case? ...

Bids conditional upon financing may be considered if evidence of financing ability is clearly demonstrated and the time required to complete the financing is reasonable. ... If the answer is yes the application of paragraph 18(1)(b) must be considered. ... It considered alternatives and finally turned to ARC and gave it a broad mandate to consider all possible solutions. ...