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All payments made by Rupert to Eldorado since May 19, 1987 will be considered as payments for the renting of the surface plant for the bene fit of Radisson. 3. ... The greater part of the amount disallowed was the cost of acquiring exploration equipment, a cost which the respondent considered did not represent CEEs. ... The Minister indeed recognized this in his Interpretation Bulletin IT-151R4, where he said in para. 15: 15....While all expenditures on SR & ED may be considered expenditures of a capital nature, for the purposes of section 37, current expenditures on SR & ED are considered to be those expenditures that do not result in the acquisition of land, a leasehold interest in land, or property that would otherwise be depreciable property to the taxpayer. ...

In summary, then, Bastarache J. indicated that the factual circumstances of the case must be considered when deciding whether a valid partnership was created. ... (“I have considered the various authorities, but they do not give a great deal of assistance. ... It depends on the circumstances of each case, and the terms of the arrangement must be fairly considered as a whole..”); Gallo v. ...

Sheikh states that BMO Financial Group considered the legal advice provided in determining the accounting reserves for NBI’s 2016 taxation year regarding the share repurchase agreements. ... The Court stated, more generally, “[i]n practical terms, this means that the Minister cannot enlist taxpayers who maintain TAWPs to perform the core aspect of audits conducted under the Act.” [148] In Atlas Tube, the Court considered the application of BP. ... The Court carefully considered whether and how BP applied and found that it had a more limited application than asserted, noting at para 63: However, I agree with the Minister’s interpretation of the limited application of the decision in BP. ...

A-20) and explained that IA had gone through an important transition in the early 1990’s when it absorbed another insurance company with about 170 sales agents who were all considered independent contractors. ... She regularly reported to her sales manager and considered her a “coach”. ... He explained that sales were a function of the number of meetings and transactions per week. [108] Meeting with the sales manager were not considered compulsory but they were generally in high demand for advice and a second opinion. ...

As to the accident policies, the applicability of Section 3(1) (j) was to be considered without reference to any decisions bearing on the corresponding provision of the U.K. ... AS indicated, I have considered the matter on the assumption that the Ontario Insurance Act is applicable and on the basis that the deceased’s estate was nominated as beneficiary under the Group Policy. ... They cannot be considered “bakers’ biscuits” as intended by Schedule III. 3. ...

I infer from the evidence considered as a whole that the amount of Points purchased by Members for cash was nominal compared with the Points accumulated by Members in connection with spending on their Amex credit card. ... The accumulation of Points and the obtaining of Rewards is considered by MRP Cardholders to be an additional benefit. ... I considered a similar series of facts in my recent decision in PC Bank. ...

The Appellant filed its Answer to the Amended Reply on July 6, 2018. [8] In paragraph 35 of the Notice of Appeal, the Appellant says that the issues to be decided in the Appeal are: (a) Can the principal reason for the agreement of the partners of Action LMS LP to share partnership income and losses pro rata, based on the number of units held by each partner, reasonably be considered to be the reduction or postponement of the tax that might otherwise have been or become payable under the Act? ... However, having considered the explanations given by Mr. Thompson and the Appellant’s counsel for refusing to answer the Disputed Mindset Questions, I understand that they are of the view that those questions cannot be answered without disclosing privileged information. ... Putnam’s Sons, 1985), p. 339. [13] Situations where the courts have considered intent, purpose and motivation, when applying subsection 103(1) of the Act, are Penn West Petroleum Ltd. v. ...

She considered it illegal competition at the time because they were cutting the native person on the Reserve out of the supplies; (x) When she met with the CRA auditors, they told her of the consequences if she was an agent or if she was purchasing on her own account. ... She testified that only Roberta MacNaughton was considered to be the Lumsden customer, and not any of Roberta MacNaughton’s customers (or their customers). ... This issue was considered by Lumsden in the context of the steps it was considering for the collection of the approximate $320,000 Roberta MacNaughton owed Lumsden after the armed robbery at her store. [150] In this case, the Minister alleges that there was GST leakage within the supply chain for the sale of the Tobacco Products. ...

This statutory concept of “unduly’’ or “artifically” has been considered in many contexts, including so-called sham transaction and artificial transaction matters. ... Sham Transactions Sham transactions as considered in the cases appear to be transactions in which the taxpayer has used various technicalities or devices for the purpose of tax avoidance. ... This was a well-considered scheme adopted on the advice of professional advisers after other means of extraction of the undistributed income—including payment of a tax under the provisions of s 105(b) of the Act—had been weighed and rejected. ...

The Queen, 2018 TCC 182 where Miller J. considered whether the taxpayer was precluded from relying on certain arguments due to the application of the large corporation rules. ... Canada, 2002 SCC 28, where the Court turned its attention to the phrase, “in respect of” noting that although it suggests “a broad set of connections,” it is not of “infinite reach” and a “proper approach to statutory interpretation” requires that the entire context be considered. ... I reject the notion that RBC was involved in an endeavour. [115] In Amex Bank, Hogan J. considered the bank’s claim for ITCs on the redemption of reward points and concluded that they were “incurred in respect of a liability that arose because of the supply of an exempt financial service” (para. 75). ...