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Gagnon was not considered to be an employee of the appellant company in this instance. ... Gagnon is not be considered an employee of the appellant company concerned and since I have so ordered, I also so order concerning Ms. ... I have already noted that the collective agreement between the employers and the workers is a factor to be considered. ...

If so, can the transactions reasonably be considered to have been undertaken primarily for a purpose other than to obtain a tax benefit? ... Can the Second Loan to REFCO ($200 million) reasonably be considered to have been undertaken primarily for a purpose other than to obtain a tax benefit? ... Further, the nature of the business aspect of the transaction must be carefully considered. ...

Still, she considered herself a freelance stylist. She negotiated a pay rate of $35 an hour – had no deductions taken from her pay and received no benefits. ... She considered herself as a freelance independent contractor although she acknowledged she was told by Pi Media that that was how she was being retained ...   [132]   To conclude my findings, with respect to senior stylists, I will very summarily comment on the traditional factors considered in cases such as these ...

Gingras and his spouse were away from home should not be considered  taxable benefits ... Gingras whether the central councils had considered increasing the remuneration of elected executives, he responded that this was an issue of affordability ... Should these compensatory payments be considered as a fixed or ascertainable stipend or remuneration? ...

She considered herself- and the person fulfilling the role of Office Manager- as the only employees of Stages. ... She relied on word of mouth advertising and considered herself to be a professional dance teacher carrying on her own business. ... Rand testified she had worked on cruise ships and was considered to be an independent contractor while carrying out that task. ...

He also cancelled the private disability insurance that he had as an employee of Gastops Inc., because he would no longer be considered to be a resident of Canada and he no longer had employment income to insure. ... (Ibid) The Respondent relied on the following cases where an individual in a fact pattern similar to that of the Appellant was considered ordinarily resident of Canada. ... All of the group's "traits, history and circumstances" must be considered in evaluating whether the legislation which imposes differential treatment on the Appellant has the effect of demeaning his dignity. 33. ...

Tailleur’s complaint further because he considered any further investigation unnecessary. ... It also means that the exercise of language rights must not be considered exceptional, or as something in the nature of a request for an accommodation.  ... To comply with the OLA requirements, the CRA in fact considered all possible reasonable measures in an attempt to reconcile Part IV and Part V of the Act. ...

However, if I am wrong in reaching this conclusion, the use of the Mark asserted by Live has also been considered. ... It must be considered in its proper context as a conclusion arising from the facts of HomeAway and not as a general principle. [86]   In HomeAway, HomeAway advertised third parties’ homes for rent on a US based website. ... Justice Hughes found use of the trade-mark in Canada based on the particular facts. [87]   In UNICAST, Justice Noël commented that Justice Hughes’ statement at paragraph 22 of HomeAway must be considered in context. ...

The parties considered the importance placed by the Supreme Court on the past and ongoing participation in a shared culture, in the customs and traditions of a community in an identified geographical location. 22.   ... The Parties considered the importance placed by the Supreme Court of Canada in Powley on the past and ongoing participation in a shared culture and in the customs and traditions of a community. ... Abbott, failed to make the inference permitted by Section 16. [182]   This very argument was considered and rejected by the Appeal Master in earlier decisions. ...

Conclusion re Costs for Tax Appeal [40]   Having duly considered the parties’ submissions on the relevant factors and considerations, I am satisfied that $6,500 would not be a satisfactory contribution by the Respondent towards Univar’s costs. ... The discretion in 147(1) is extremely broad—it gives the Court total discretion in terms of (1) the amount of costs; (2) the allocation of costs; and (3) who must pay them. 12 Rule 147(3) provides the factors to be considered in exercising the Court's discretionary power. ... Words found in legislation are not generally considered redundant. As stated by the Supreme Court in Hills v. ...