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The assessor testified that she considered three possible methods of allocation. ... When the income statements are considered it seems very unlikely. In any event, his evidence on the point was both vague and uncorroborated, and I would not rely on it. [22]          The remaining method is to allocate in proportion to the contributions to revenue of the commercial and non-commercial activities. ...

Have you ever considered the fact that, even to film an interior scene, we have to install lighting outside? ... He did so for various reasons, referring in particular to the following: ·             the particular characteristics and requirements of his work; ·             according to him, the Act did not take into account the new reality in the film production industry; ·             the unreasonable and inappropriate nature of the requirements of the Act. [15]          The various grounds cited by the appellant to justify his behaviour may be quite legitimate in his view, but they have no legal merit and may not be considered by this Court, which is essentially bound to follow and apply the provisions of the Act. [16]          In view of the evidence, I must dismiss the appeal. ...

(as he then was) considered what constitutes the operation of a business and concluded that "although originally disputed, it is now accepted that in order to have a 'source of income' the taxpayer must have a profit or a reasonable expectation of profit". ... The following criteria should be considered: the profit and loss experience in past years, the taxpayer's training, the taxpayer's intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...

Cayer and one of his co-workers put it this way: “ We have considered taking control of this operation and maximizing the liquidation process; however, this alternative would expose us to a loss. ... He considered it important to pay them those amounts just before the Christmas holidays because of the low wages they were earning. ...

Thus at the end of the day all of the facts must be considered and all of the relevant criteria or tests enunciated in the case law must be applied. [12] The expression "at arm's length" was considered by Bonner, T.C.J. in William J. ...

Thus at the end of the day all of the facts must be considered and all of the relevant criteria or tests enunciated in the case law must be applied. [15] The expression "at arm's length" was considered by Bonner, T.C.J. in William J. ...

The Contractor shall not, without the express written permission of Her Majesty, divulge or use such Technical Information and Inventions, other than in performing the Work under this Contract, and shall not sell other than to SPAR under this Contract, any articles or things embodying such Technical Information and Inventions. [3] [11] Spar included the foregoing clause in its contract with Com Dev, but also included the following diminution modification clause: 12.7 The information detailed in the Contractor's letter dated April 19, 1990 is considered proprietary to the Contractor or its Subcontractors as the case may be. [4] [12] The letter referred to in clause 12.7 and filed as an exhibit in this proceeding reads as follows: April 19, 1990 File: 5050 Ref.: JB-1578 SPAR Aerospace Satellite and Communications System Division 21025 Trans Canada Highway Ste. ... Statement of Proprietary Information In accordance with the conditions of the RADARSAT Contract between SPAR Aerospace and COM DEV, S-700014, Article 12 – Intellectual Properties – this will certify that all equipments, associated Technical Information and Technical Documentation to be generated in performance of the Work and considered deliverable under the contract will utilize computer software, processes, methods, techniques and know-how in existence or residence with COM DEV prior to effective date of the Contract. ...

., supra, the Federal Court of Appeal laid out certain matters which should be considered by this Court when hearing these appeals. ... She explained in clear terms what her duties and responsibilities were, why they were worth the amount that she was paid and how relative to what she had earned four years previously in an office position it could not be considered excessive. ...

Her Majesty the Queen, 96-905(IT)I and 95-2380(IT)I, at pages 12-13: In my view, this tax advantage should not be considered in determining whether Dr. ... The tax advantage which is received from gifts is not normally considered a ‘benefit’ within this definition, for to do so would render the charitable donations deductions unavailable to many donors. [39] Judge Archambault continued as follows: Nor was the gift a sham. ...

To do so, these individuals use the bags of coffee left on the premises by the technicians which are considered to be part of the appellant's inventory. ... Although most of the automatic vending machines contain a money changer, the technicians do not remove the money as it is considered the property of the appellant's customer, which has decided to charge coffee consumers—its employees, customers or other persons—a predetermined amount rather than offer them coffee free of charge. ...