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At worst, the IGA is still a binding agreement between the US and Canada respecting the interpretation or application of the Canada-US Tax Treaty, and as such may be considered in interpreting the latter, which is a treaty pursuant to the Vienna Convention on the Law of Treaties, Can. ... Considering that such information would not be provided in relation to accounts held by Canadian nationals who are not considered US persons, the plaintiffs assert that the impugned provisions fall afoul of this Article. ... (Transcript, August 5, 2015 at page 133). [76]            True, a great number of Canadian taxpayers holding US reportable accounts are likely to be affected by a reporting system that in many quarters is considered unjust, costly and ineffective, considering that at the end of the day they are not likely to owe taxes to the US. ...

This Court considered the matter anew, and concluded that, as the taxpayer spent about the same amount of time on farming and his other source of income, but had invested less capital in the farm and earned less income, his chief source of income was not farming. [65]            The third case is Canada v. ... In doing so, he considered only Mr. Gunn’s argument that the financial success of his law practice is attributable in part to a synergy between it and his farming operation. ... When all of that evidence is considered in light of Mr. Gunn’s evidence as to the ways in which his law practice is enhanced by the factual connection between the farm and the law practice, I would conclude that even on the Moldowan interpretation of the combination question, the answer to the combination question is yes. ...

Upon more considered reflection, I still adhere to that view. It is clear from Section 13 of the Quebec Mining Act that every mine in the Province of Quebec is liable for duties upon a graduated scale dependent upon the amount of the annual profits. ... -G. for Ontario, [1966] 1 O.R. 349, the Ontario Court of Appeal considered whether the tax imposed by Section 4 of the Mining Tax Act, R.S.O. 1950, chapter 237 was ultra vires of the province as not being ‘‘direct’’ as it must be to fall within the taxing authority conferred on the province by Section 92 of the British North America Act. ... Imperial Oil Limited, [1960] 8.C.R. 735; [1960] C.T.C. 275 the Supreme Court considered Section 1201 of the Regulations in its earlier form. ...

Obviously, we also did not want any picketing because the Admiral employees were unionized, and we considered that our social role was to pay the employees’ wages. ... The latter stated: ”... we considered that our social role was to pay the employees’ wages” (2.04.2). ... It must also be considered that, by virtue of subsection 153(3) the employees are deemed to have received their wages in full, so that they are liable for income tax on that basis. ...

Both counsel considered this disparity to amount to nothing more than a typographical error, and both agreed that nothing turns on it. ... Further, I am satisfied that this is an issue with respect to which evidence extrinsic to the document itself may be considered. ... Only two questions remain to be considered and these arise from the provision in the amending agreement for arbitration on the terms of the formal agreement. ...

Secondly, a distinction is sometimes drawn in the cases between transactions which are to be treated as "investments" and those which are to be considered as “speculations”. ... The appellant never considered selling the debenture to anyone else. From the moment he purchased it, he intended to redeem it. ... M.N.R., [1989] 2 C.T.C. 94, 89 D.T.C. 5357, whose learned and considered judgment was later confirmed by the Federal Court of Appeal. ...

However the Articles of concordance are of relevance when the characterization of maritime jurisdiction is to be considered: Reference re Offshore Mineral Rights of British Columbia, 1967, infra. ... This leads us to the much-debated question whether, and to what extent, the Exclusive Economic Zone can still be considered part of the high Seas.... ... The Supreme Court of Canada in Reference re Offshore Mineral Rights of British Columbia 1967, supra, considered the Direct United States Cable Company, supra, decision and concluded, at 809, that the case turned on the fact that. there was legislation of the Imperial Parliament... which asserted exclusive dominion over the Bay.” ...

In paragraph 14, the Court wrote: A sum is considered certain when it can be made certain. ... One argument considered by President Jackett was whether the resulting difference in value constituted a debt or encumbrance as those two types of obligations were permitted statutory deductions in computing the aggregate net value of an estate. ... In several provisions a “note” is expressly considered indebtedness or a debt obligation. ...

Both actual receipts and amounts credited but not paid (i.e. accruals) are considered to be income liable to profits tax [Tab W at 12.1]. ... According to the CCRA, Hong Kong can only be considered part of the PRC for purposes of the Treaty if the laws relating to Chinese tax apply to the HKSAR. ... A resident of Hong Kong who is subject to Hong Kong's tax regime (and not that of the PRC) would not be considered a resident of the PRC. ...

Pai brought her two children whom Lazic considered were well-behaved and had not caused any disturbance. ... Lazic stated there was no problem with Malabanan’s claim for UI benefits but considered Pai was evasive about several matters and was not forthright when responding to straightforward questions. ... She considered the language school, RTI, to have been a legitimate business operation or at least a functioning entity. ...