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There are similarities between the avoidance transactions in the present case and those considered in Descarries that allow me to conclude that the avoidance transactions in the present case were, like Descarries, designed and implemented in a surplus-stripping context involving a complex plan. ... In adopting GAAR, Parliament recognized that specific anti-avoidance rules such as section 84.1 often proved to be ineffective in curtailing tax avoidance arrangements considered by Parliament to be abusive. ... A                        Again, that was under the direction of MNP. 258   Q                        Can you ask MNP whether they considered having 125 issue separate classes of shares, and advise of their answer?                         ...

However, the fact remains that it is considered together with resemblance and acquired distinctiveness. ... With respect to the goods and services in this case, I believe that they must be considered to be ventilation and heating. ... Instead, it is “all the surrounding circumstances” that must be considered. ...

And the other thing that would be considered is external obsolescence. ... He testified that he considered the 27 Cardigan case, [57] in which the Federal Court of Appeal applied a 10% discount. ... Duda’s assertion that he considered the market evidence contained in the Rokeby analysis and took into account the specific circumstances of the Richmond property was not successfully challenged. ...

With respect, the issues to be considered in addressing the above concerns hardly parallel those facing Mr. ... Confusion has arisen in this case because it was considered on the basis of solicitor-client privilege. ... It is the substance of the public interest question which must be considered. ...

Riordon herein dated the 29th day of November, 1993 may also be considered by this Court in reaching a conclusion in the "Askov’’ application. ... Justice Riordon indicated was conduct that could not BE CONSIDERED TO BE ENTIRELY STRAIGHT FORWARD and swore out an affidavit or information that in the words of Mr. ... The Supreme Court set out four factors to be considered by a Court contemplating an order staying proceedings based upon unreasonable delay in bringing a case to trial. ...

These proceeds of approximately $560,000 for 1985 and $490,000 for 1986 are considered by the appellant as proceeds of disposition of capital property under the Income Tax Act, R.S.C. 1952, c. 148 (am. ... The expenditure was considered to be on capital account. In defining the word "plant", Lord Reid adopted the often-quoted words of Lord Lindley, L.J. in Yarmouth v. ... The other points (demurrage and cost of cylinder) are incidental and the nature of the amounts received concerning them is of the nature of those received for gas: they are of business nature. 4.03.2 (5) Can the payment of the cost of the lost cylinders be considered as damages? ...

As noted in Royal Winnipeg Ballet at para. 64, the relevant factors must be considered “in the light of” the parties’ intent. ... Other Factors [46] As indicated in Wiebe Door, Sagaz and the other cases discussed above, there are several additional factors to be considered in determining whether a worker is an employee or an independent contractor, as listed in paragraph 33 above. 1. ... Dahlen considered himself, at least on that occasion, to be working for UPA. [57] Mr. ...

Although the ordinary meaning of “subsidiary controlled corporation” cannot be considered, it is important to add that the words of the given definition of the expression themselves must be construed in their ordinary meaning. ... However, the word there being considered was the word “controlled” as used in section 39(4)(b) of the Act. ... Company “B” with its 89 shares could not be considered within the exception. ...

The appellant argues that this unconstrained discretion cannot be considered a "right" which is conferred by the shares. ... Rather, it is the entitlement to be considered for a dividend which is more properly characterized in those terms. ... That cannot legitimately be considered as within the parameters of the legislative intent of subsection 56(2). ...

In Oceanspan Carriers Ltd v Canada, [1987] 2 FC 171, 1987 CanLII 9009 (FCA) [Oceanspan], the Respondent argues that the Court determined that a non-resident corporation, which did not earn income from Canadian sources, could not be considered a “taxpayer” under the ITA. ... However, the parties disagree regarding whether residency must be decided first; that is, whether it must be considered prior to applying sections 231.1 and 231.7 of the ITA. [75] The Applicant refers to Ghermezian v Canada (Attorney General), 2020 FC 1137 [Ghermezian 1], where the Court cited Lin. ... In assessing the meaning of the word “individual,” as it was used in section 118.5(1), the Court considered the purpose for which it was used and the surrounding language. ...