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  [82]     Finally, the Federal Court of Appeal also considered the question of the nature of the remedy provided by section 19 of the Federal Courts Act in The Queen in right of Canada v. ... If not for the increase in its mark-up rate in 1991-1992, therefore, Loto-Québec considered that it would have sustained a decrease in revenue of $11,972,637 ... That was the case with SOQUIA in 1994 when the Quebec application was considered. ...

In Cameco Corp. v Canada, [23] Chief Justice Rip (as he then was) considered proportionality in the context of discovery in a transfer pricing case. ...   [197]    Any such requests from Burlington speak to the factors considered in determining the guarantee fees and fixing the amount. ... Court’s Decision [236]    I agree with Burlington that Questions 4014-4015, 4020-4021, as asked during the examination for discovery “is whether JP Morgan, considered the hybrid nature of the transactions”. ...

The Director of Military Prosecutions has issued a policy directive on the factors to be considered when determining whether charges against a person who is subject to the CSD should proceed in the military justice system or instead in the civilian criminal justice system. ... Overbreadth and legislative competence are not the only guides to defining the meaning of s. 11(f) — the right contained in that section must be considered. [122]                      Third, military court jurisdiction has historically been subject to important limits. ... Historically, the local community’s interest in adjudicating alleged crimes committed against it and the importance of a public example were considered key parts of the criminal jury trial right. ...

Blair has (quite properly) not considered the manner in which this Court, for the purposes of the ITA, should view the Trades. ... Noël, C.J. simply found that the transactions in Paletta had the “appearance” of being commercial but in fact were not “clearly commercial” when one considered all the circumstances. [197] [Footnote omitted.] ... However, where the activity could be considered a personal pursuit, then one must ask if the activity is being carried on in a sufficiently commercial manner so as to be a source of income. [200] [Footnotes omitted.] ...

Wescast considered Linamar to be a good fit because of Linamar’s technical capability, its need for a casting supplier and the diversification opportunities for Wescast.   9.                  ... I admitted her evidence, over the objection of counsel for the respondent, as I considered that her opinion might be useful in determining the question before me ...   [30]     Counsel for the appellant argued that if these payments are considered to be on capital account then the Minister will treat them as capital “nothings”, to the taxpayer’s great detriment. ...

"   [31]     The "connecting factors" test was considered by the Federal Court of Appeal in Canada v. ... We should indicate that the concept of "commercial mainstream" is not a test for determining whether property is situated on a reserve; it is merely an aid to be used in evaluating the various factors being considered. ... What is "extremely important" is the type of income being considered as attracting tax. ...

Each supply must be considered as an independent supply for tax purposes, the single consideration being apportioned among the separate supplies as appropriate.          ... One factor to be considered is whether or not the alleged separate supply can be realistically omitted from the overall supply. ... Whether the services are rendered under a single contract, or for a single undivided consideration, are matters to be considered, but for the reasons given above are not conclusive. ...

Reference was also made to the fact that there were minority shareholder interests to be considered in the case of Indal. ... Stracey considered Mr. Paterson to be his boss (see his evidence re: being asked by Mr. ... Implicit, if not explicit in the Stubart decision is the admonition that arrangements (or transactions) which lack a bona fide business purpose are to be considered within the context of subsection 245(1) of the Act. ...

All four were considered purchasers since all four contributed to the purchase price. ... His actions and his intentions are those of primary concern here, for the others ultimately followed his lead and must be considered to be bound by the intentions of Joe lula. ... In other words, I do not believe that he considered selling only after an offer too good to refuse was made. ...

  [19]        Since the income on which the U.S. tax was paid was not considered to be income under the Act, there was no source of income to the limited partnership against which the subsection 20(12) deduction could be taken ... Although what the taxpayer owns is the shares of ULC which is a Canadian corporation, the U.S. taxes paid can be considered to be in respect of such shares such that the deduction under subsection 20(12)... would not be denied... ... Dividends from those shares could not be considered income from the share of a foreign affiliate, since NSULC was a Canadian corporation and not a foreign affiliate of Dorr-Oliver ...