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The Court was of the view that municipal zoning provisions dealing with minimum size requirements and subdivision restrictions were factors to be considered at the time of disposition and also at the time of acquisition of the land. ... This was refused, among other reasons, because the retained portion was far in excess of 45,000 square feet, the maximum considered to be acceptable for a residential lot. ...

The Minister however considered the remainder of the $45,000,000 settlement to have been made in respect of penalties. ... As I have concluded above, a fine or penalty cannot be considered to have been incurred for the purpose of producing income unless in all the circumstances the incurring of the fine or penalty must be seen as an unavoidable incident of carrying on the business. ...

The Minister considered the payment by the appellant to be a deemed dividend under section 212 of the Act. ... While the relevant legislation is complex, it cannot be considered meaningless. ...

The Regulation 105 withholding does not represent a definitive tax, rather the withholding is considered a payment on account of the non-resident's overall tax liability to Canada. ... Revenue Canada does not agree, taking the position that [t]he Regulation 105 withholding does not represent a definitive tax, rather the withholding is considered a payment on account of the non-resident's overall tax liability to Canada....                 ...

The Trial Judge concluded from this history and these statutory provisions that the ferry terminals or landings on which the work was done in this case were at all relevant times part of the provincial highway system under the jurisdiction of the Department of Highways, and as such could not be considered to be a public utility within the meaning of subsection 44(2) of the Excise Tax Act. ... For instance, in 9(1) we have “the Board shall determine whether a unit is appropriate”; “the Board may... include additional employees in the unit”; “the Board shall take such steps to deter- mine the wishes of the employees”; 9(4) “the Board... may, for the purpose... make such examination of records or other inquiries, etc.”; “the Board may prescribe the nature of the evidence to be furnished”; 9(5) “the Board, in determining the appropriate unit, shall have regard to the community of interest’’; 9(7) “if the Board is not satisfied... it shall reject the application and may designate the time before a new application will be considered”; s 11, the Board “may revoke the certificate”. ...

In my opinion, it cannot, therefore, be considered as support for the appellant’s contention that the separate existence of Garyray was unrelated to tax advantages. ... I think the statement of Lord Upjohn in /RC v Brebner, [1967] All ER 779 applies in the present case, at 784, where he said: My lords, I would conclude my judgment by saying only that, when the question of carrying out a genuine commercial transaction, as. this was, is considered, the fact that there are two ways of carrying it out—one by paying the maximum amount of tax, the other by paying no, or much less, tax—it would be quite wrong as a necessary consequence to draw the inference that in adopting the latter course one of the main objects is for the purposes of the*'section, avoidance of tax. ...

In this vein, Pratte, J, speaking for the Supreme Court in The Queen v Compagnie Immobilière BCN Ltée [6] said: One of the most important rules to be followed in the interpretation of a particular provision of a statute was expressed as follows by Lord Herschell in Colquhoun v Brooks, [1889] 14 AC 493 at p 506: “It is beyond dispute, too, that we are entitled and indeed bound when construing the terms of any provisions found in a statute to consider any parts of the Act which throw light upon the intention of the legislature and which may serve to show that the particular provision ought now to be construed as it would be if considered alone and apart from the rest of the Act.” ... Its meaning has, however, been considered many times. In MNR v Irwin,’ [7] Abbot, J, speaking for the Supreme Court, referred to it as follows: The basic concept of “profit” for income tax purposes has long been settled. ...

.), considered a tax planning scheme wherein the taxpayer borrowed money in order to lend that money to its U.S. subsidiary. ... Judge Bowman found that the overriding purpose of the loans was not to earn income, but rather to permit the subsidiary's losses to be imported into Canada and deducted in computing the parent's income. 33 He said at the top of page 1010: Considered separately neither of these elements justifies a disallowance of the interest paid under subsection 245(1). ...

That kind of property is considered a movable and does not require the wife's consent. 4.03.1.3 Moreover, according to the respondent, since the term “security" is not defined in the Act, we must look to its ordinary dictionary meaning. ... He concluded therefore that the third requirement of paragraph 20(1)(bb) had also not been satisfied. 4.03.1.6 With respect to the second requirement of paragraph 20(1)(bb), however, counsel for the appellant alleged that the theory that only the ordinary or grammatical meaning may be considered when the word is not defined in the statute in question nowadays admits of exceptions. ...

. ·         Liability under Contract/Liability for Payment:  Where a person purchases goods on behalf of another person and the other person is liable to pay for whatever it is that the supplier has sold, the person acting on behalf of the purchaser is considered to be an agent of the purchaser. ·         Ownership of Property:  Generally, an agent does not acquire an interest in any property the agent acquires as agent on behalf of the principal.  ... ]   [23]       Other cases have considered the importance of the ability of an agent to affect the legal position of the principal and the assumption of risk by the principal, and reach the same conclusion.  ...