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In arriving at this position Revenue Canada considered the following facts: 1. ... The planning document prepared by Young was also considered a factor. ... The criteria enunciated in IT-419 have also been the criteria consistently considered by the courts. ...

Section 24(2), and its application, was very recently considered by the Supreme Court of Canada in R. v. ... The “results”- fruits- of the execution of the search warrant may not be considered on the motion to quash; only the “contents” of the information filed in support of the issuance of the warrant may be considered. ... Counsel for the accused has referred me to numerous other cases, all of which have been considered. ...

I have identified below where I considered any such information useful ... For this purpose only one arm’s length transaction is considered, that involving McKesson Canada and TD Factors. ... That is, it was not that TDSI considered a 2.5 times multiple reasonable, it considered a 6 + times multiple reasonable but did not expressly say so ...

The Dunham Report considered the 10% interest rate paid on these loans to be excessive. ... Dunham considered these loans to be quasi equity that posed no financial risk to the company, whereas Mr.  ... What would be in the industry for the President of the company, my salary is considered low. ...

Canada. [3] [15]         In that decision the Supreme Court set out what constitutes “control” and what is to be considered in the course of determining whether someone has “control” of the corporation. ... I might add that I considered for this purpose whether Kruger controls the appellant’s pricing. ... The particular factors considered are in section 6.2.2 of the expert report, Exhibit A-7; the same report is also at Exhibit A-8 which attaches many supporting documents. ...

Such time spent was considered to be related to his work (Examination of Lawrence Wolf, Appeal Book, vol. 2, p. 41, lines 6 to 23) ... I am comforted in this conclusion by the fact that Kirk-Mayer also considered the appellant to be its employee. ...   [79]            The Tax Court judge considered in addition, at paragraph 26 of her reasons, what she referred to as  “the specific result test”.  ...

Professor Klein agreed that the size of the primary market for OTC currency options is considerable when transactions by all market participants are considered. ... It is difficult if not impossible to say that where only value is being considered in which a variable inheres you can have any other than a fluctuating estimate. ... Under s. 9(1), deductibility is ordinarily considered as it was by Thorson P. in Royal Trust, [Royal Trust Co. v. ...

Champagne in the course of his job in the economic crimes section and considered him an expert on paintings. ... The search was part of an investigation into what Revenue Canada considered a tax scheme. ... She considered the appearance and weight of the box, which was made of solid silver. ...

Travel to and from the employee's home and the place of employment is considered to be personal. ... However, he also considered the tests set out in Wiebe Door Services Ltd., supra, and determined that they were not conclusive either way. ... The Court agrees that that is a factor to be considered in the present case but it is not conclusive. ...

Any customer warranty was provided by the manufacturer of the cell phone but Balanko stated he considered customers who dealt with him to be his own clients. ... Peters stated she considered her services had to be provided personally and, when working with Quaife, one of them always ensured the store was staffed. ... No. 239, I considered the matter of a worker who was engaged in selling pay phone installations to businesses. ...