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Competent authority agreements are not considered precedents for either the taxpayer or the CRA in regard to (re)assessments relating to subsequent years or for competent authority negotiations on the same issues. ... A taxpayer cannot accept the terms of an agreement for only some issues or taxation years involved, since the original request by the taxpayer would have asked for assistance in respect of all issues and taxation years involved and the competent authorities would have considered all issues and years in the negotiations. 55. ... Subbiah’s statements can be considered an admission and therefore an exception to the hearsay rule: see, generally, paragraphs 6.408 to 6.416 of Sopinka, Lederman & Bryant: The Law of Evidence in Canada, 4th ed. by Sidney N. ...

It is not established that O’Donnell 2004 was considered to be part of common general knowledge. ... The article did suggest that they should be considered “active hormonal agents for prostate cancer.” ... This was not considered to be a significant suppression of cortisol and therefore was not a major concern. ...

The question of what is fair market value for inventory purposes was considered in Sellers-Gough Fur Co. ... He considered putting it into the company safe, but discarded that idea because the company had only a light safe and no burglar alarm protection. ... The subjective statements of intention by the plaintiffs must be considered along with objective facts. ...

The search was part of an investigation into what Revenue Canada considered a tax scheme. ... He also considered that the prices suggested in the Guide Vallée are real prices for gallery sales and need not be checked. ... The concept of fair market value has been considered by the courts, inter alia in Henderson v. ...

In the context of other provisions of the Act, including subsection 169(1), the courts have considered on a number of occasions whether an input was made “in the course of” a “commercial activity”. ... The Supreme Court of Canada stated that: [50] … [c]ontractual interpretation involves issues of mixed fact and law as it is an exercise in which the principles of contractual interpretation are applied to the words of the written contract, considered in light of the factual matrix of the contract. [36] The Supreme Court of Canada also turned its attention to the role and the nature of the surrounding circumstances in contractual interpretation and the nature of the evidence considered: [57] While the surrounding circumstances will be considered in interpreting the terms of a contract, they must never be allowed to overwhelm the words of that agreement (Hayes Forest Services, at para. 14; and Hall, at p. 30). ... I surmise that PC Bank considered that the cost and efficiency savings attributable to the outsourcing of services to FDR and then to TSYS was of greater value than the GST that PC Bank self‑assessed on the TSYS supply. [156] Ms. ...

Winding-up was not in contemplation and cannot be considered as probable in the case of this old and well-established company. ... (a), (d) or (g) affect duty on the restricted shares can be better considered after the general discussion of principles. ... There are two lots of the ordinary shares in these private companies to be considered; those which were actually held by the late G. ...

At the same time, “just as the text must be considered in light of the context and object, the object of a statute and that of a provision must be considered with close attention always being paid to the text of the statute, which remains the anchor of the interpretative exercise” (Quebec (Commission des droits de la personne et des droits de la jeunesse) v. ... The purpose of the specific provision must be considered in the context of the broader purpose of the BIA. ... Finally, “program of studies” is stated to be “the series of periods of studies that is considered by the designated educational institution to be necessary to obtain a degree, certificate or diploma” (s. 2(1)). ...

    [58]         I would also note that the issue of whether regulatory charges are a tax was not directly considered in Lawson, and was obiter in the reasons of the majority in Home Builders. ... Quite simply, although regulatory charges were once considered taxes for constitutional purposes (e.g. ...   [83]         The other provision relied on by Mattamy, subsection 296(2), is the relevant provision to be considered. ...

(3)       If so, can the transactions reasonably be considered to have been undertaken primarily for a purpose other than to obtain the tax benefit? ... Justice Rothstein in OSFC Holdings Ltd. stated at paragraph 46:             The words "may reasonably be considered to have been undertaken or arranged" in subsection 245(3) indicate that the primary purpose test is an objective one. ... Since the test here is an objective one, it is the relevant facts that are to be considered and not the taxpayer's intention. [91]     Which provisions are being misused? ...

Justice Taylor considered that by making that argument the petitioners had already elected their relief under subsection 24(1) of the Charter, and had not been subjected to double punishment. ... Justice Taylor considered that those submissions constituted an election of a remedy under section 24 of the Charter and precluded the petitioners from arguing that they were being punished twice for the same offence. ... In affirming Toy, J.'s decision the Court considered the judgments in Wigglesworth (which was handed down after Toy, J's decision), and Trumbley and Pugh v. ...