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The amount of the benefit as determined could have been considered normal and reasonable in the circumstances if the cottage in question had been put at a shareholder's disposal without any limitations or during a rental period for his vacation. ... I am satisfied that in many cases that could be considered a disadvantage rather than an advantage ...

Not until the spring of 2006, was it determined the Losses were not considered as losses in 1999. ... Hoffman that his August 25, 2009, letter be considered his notice of objection ...

Analysis   (1) General principles of profit computation   28     In the relatively recent case of Symes, supra, this Court considered the general principles which govern the computation of profit for income tax purposes. ... Under s. 9(1), deductibility is ordinarily considered as it was by Thorson P. in Royal Trust, [Royal Trust Co. v. ...

On May 17, 2007, the Honourable Justice Alain Tardif of the Tax Court of Canada allowed the appellant's application to extend the time for appealing in respect of the 2001 year, and the Notice of Appeal attached to the application was considered to be valid and deemed to have been filed with the Tax Court of Canada on the same day. 7.                   ... (p)          The Minister considered that the amount of $58,206 that the appellant had transferred from her locked-in retirement account to the CCCC pension plan, revoked on July 24, 2000, was not a transfer of funds between registered plans, but that that amount was received by the appellant in the course of 2001 as a benefit from a registered retirement savings plan. ...

during the period under appeal, the Payor engaged the services of another worker (the “Other Worker”) and considered the Other Worker to be a sub‑contractor; (no knowledge)   h.        ... Grant (the “Other Worker”) and considered him to be a subcontractor. I would point out immediately that the Other Worker testified that Mr.  ...

Canada, 2005 FCA 131, [2006] G.S.T.C. 52, in the Federal Court of Appeal and Rule 9(2) as well as the decisions of this Court which have considered the relationship between cost awards and abuse of process such as Bono v. ... I have considered the Appellant’s position in the Notices of Appeal, and his comments and submissions today in the context of the considerations applicable to awards of costs generally and to how best regulate abuses of process, which are summarized in the cases I have referred to and in our court’s rules. ...

Based on the access granted in the court order, you do not have the children 50% of the time and therefore, are not considered the primary care giver of the children.   ... I believe this is an important new fact, and it should be considered when determining the primary caregiver or shared eligibility ...

The intention of the parties is a significant and material guideline or criteria to be considered along with all of the other considerations. ...   [34]          I must acknowledge that there were two aspects of the evidence that could be considered unusual. ...

Thus, where the nature of a taxpayer's venture contains elements which suggest that it could be considered a hobby or other personal pursuit, but the venture is undertaken in a sufficiently commercial manner, the venture will be considered a source of income for the purposes of the Act ...

Another example is section 160, in which the harshness of an open-ended assessment period was considered by the Supreme Court of Canada in The Queen et al v. ...     [48]     As for whether such expenses are deductible, a similar issue was considered in Neeb.  ...