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A director must have turned their attention to the required remittances and show that they exercised their duty of care, diligence, and skill with a goal of preventing the corporation’s failure to remit. [10] The efforts must be aimed at preventing the failure to remit rather than curing the failure after the fact. [11] [10] Under the objective standard, the director’s particular circumstances must be considered in the context of the “reasonably prudent person”. [12] The stricter standard discourages the appointment of inactive/outside directors who might tend to rely on active/inside directors to carry out directorial functions. [13] Two-year limitation [11] Subsection 227.1(4) requires the Minister of National Revenue to assess a director within two years after they last ceased to be a director of the corporation. ... However, his experience as a director seemed limited to that of an outside director and he seemed to expect a similar arrangement with Brew Street. [36] The stricter objective standard discourages the appointment of inactive/outside directors who (for one reason or other) do not discharge their duties and leave decision‑making to the active/inside directors; i.e. a director must actively carry out their duties to be considered duly diligent. [37] [37] It is very unfortunate that the appellant’s venture with Brew Street took such a negative turn. ...

Al Omani considered what particulars are required for a statement of claim. ... Since the Tax Court does not have jurisdiction to set aside an assessment on the basis of reprehensible conduct by the Minister, the applicants say recourse to this administrative law remedy should be available in the Federal Court. [24] This argument was expressly considered, and rejected, in Iris: [36] Does the allegation that the Minister breached procedural fairness in the audit and assessment process mean that judicial review, rather than a challenge to the correctness of the assessment, is the true nature of Iris’ claim? ...

" [32]     Tropper described the three separate markets that were to be considered. ... In this valuation, the appraiser has considered data from various sources (e.g. dealers, artists, authorities) and published documents (e.g. invoices, sales records) and considered that information to be reliable. ... Tropper considered the market in which CVIAM sold prints to the Appellants and others. ...

" [33]     Tropper described the three separate markets that were to be considered. ... In this valuation, the appraiser has considered data from various sources (e.g. dealers, artists, authorities) and published documents (e.g. invoices, sales records) and considered that information to be reliable. ... Tropper considered the market in which CVIAM sold prints to the Appellants and others. ...

" [33]     Tropper described the three separate markets that were to be considered. ... In this valuation, the appraiser has considered data from various sources (e.g. dealers, artists, authorities) and published documents (e.g. invoices, sales records) and considered that information to be reliable. ... Tropper considered the market in which CVIAM sold prints to the Appellants and others. ...

Kieboom to 50-50. [126] The issue considered by the Court of Appeal that is of interest here is whether Mr. ... R., [64] the Federal Court of Appeal considered the approach taken by the majority of the Supreme Court of Canada in R. v. ... The Respondent’s description of purpose implies that any transfer of property should be considered abusive if the transfer thwarts the Minister’s ability to collect a tax debt. ...

Michaud explained that it used to be considered the insurance company’s expense as opposed to the individual agent’s. ... Michaud, he is clearly considered an employee by Industrial Alliance. ... Charbonneau saw any differences between the treatment of agents when they were considered as employees before 1993 and their treatment when they were considered as independent contractors after 1992!! ...

The certification judge held, however, that this argument could not be considered at the certification stage (para. 46). ... On this point, the Court of Appeal considered that it might be relevant (on the express assumption that concerns about indeterminate liability might properly be considered outside the context of a negligence action) (C.A. reasons, at para. 227). ... S.5, which this Court recently considered in Canadian Imperial Bank of Commerce v. ...

In reaching that conclusion, the Judicial Committee considered von Glehn. ... The delictual act cannot in that case be considered as being necessary for carrying on the trade or profession. ... By order dated July 5, 2012, he required the correction of the passages he considered non-compliant with his previous order. ...

Given that intention, do the factors to be considered in determining whose business is being carried on from the fixed place of business support that intention. ...   …   38.6     Another factor to be considered in determining independent status is the number of principals represented by the agent. ... On the issue of legal independence, the Court considered:  -                      There is a separate management agreement in respect of each of the Japanese insurance companies ...