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Such conditions only add corroborative support where a transaction can be considered to be a sale under the circumstances stated in 3 above.      6. ... The meaning of the word "acquired" as used in section 20(5) was fully considered by my brother Cattanach J. in The Minister of National Revenue v. ... His interest in the property had gone far beyond that arising from a merecontract [sic] of purchase and sale of the type considered in Wardean Drilling Ltd., supra.      ...

A to B, then B to C) considered a single composite transactions, such as A to C?                                                                  ... Further, the nature of the business aspect of the transaction must be carefully considered. ... The first question is whether it may reasonably be considered that any of the avoidance transactions would result in a misuse of a specific provision or provisions of the Income Tax Act. ...

where the amount can reasonably be considered to have been received                  (iii) as an inducement,...              ... (viii) may not reasonably be considered to be a payment made in respect of the acquisition by the payor or the public authority of an interest in the taxpayer, his business or his property;... 2      Canada Tax Words, Phrases & Rules, Dictionnaire Fiscal Canadien, Carswell Thomson Professional Publishing, June 1996, pp. ...

“Reasonably be considered” by whom? [53]            The respondent argued that the definition of tax shelter that was applicable to the taxation years in issue in this appeal was further problematic in that it provided no indication as to how the reasonableness requirement of that definition was to be dealt with by the Court. ...   [55]            The respondent also raised the question as to whether the statements or representations that were made could reasonably be considered to have led to the inference or conclusion that the mathematical component of the definition of tax shelter had been met. ... It follows, in my view, that the statements in the Tax Opinion that indicated that the acquisition cost of TIP licences would be deductible to prospective investors over a two year period can reasonably be considered to have lead to the conclusion that the mathematical component of the definition of tax shelter would have been met in relation to prospective purchases of TIP licences by prospective purchasers.   ...

Tax J. 133, and by Joseph Frankovic's article, "Why Interest Should be Considered a Current Expense" (2002), 49 Can. ... Rather, it is more usually a current expense, although the purpose of the borrowing during the relevant period must always be considered. ... He concluded that, because interest could be considered either a capital expenditure or a current expense, depending on the use of the funds, paragraph 8(1)(j) was needed to expressly permit the deduction of interest when the borrowing was for a motor vehicle or aircraft which were considered to be capital expenditures. ...

The second question to be considered is whether for the purposes of subparagraph 12(1)(x)(viii) these payments should be regarded as having been made in acquisition of an interest in property. It will be noted that this subparagraph includes as income any payment which " may not reasonably be considered to be made in respect of the acquisition" of the taxpayer's property. ... In these circumstances its contribution if anything became of the nature of a grant, subsidy, or forgivable loan and cannot reasonably be considered a payment for the purpose of acquisition of property.      ...

The Minister, however, submits that subsection 152(4.3) permits the Minister to reassess only to the extent that the reassessment following the decision can reasonably be considered to relate to a change in the taxpayer's balance for the years in question. ... The reassessment for 1985 disallowing the repayment of the loan could reasonably be considered to relate to the change in the balance for 1983 and 1984. ... The reassessment requested by Sherway for 1989-91 cannot "reasonably be considered to relate to the change in the particular balance of the taxpayer for" 1987-88. ...

Therefore, in keeping with the above decisions, this factor will not be considered in assessing the costs of the Respondent. [15]   Thus in light of the Court’s rule 401 (1) discretionary powers and as outlined by the assessment officers in Latham v. ... Canada, the assessable services claimed under items 21 (a), 25, 26 and 27 are considered both reasonable and necessary to advance the conduct of the proceeding and Her Majesty the Queen’s motion to quash the appeal; they are allowed as claimed. The claimed disbursements relating to the photocopying of the motion to quash are equally considered reasonable and necessary, the quantum sought is allowed as claimed. ...

The letter invited a response by a certain date, failing which revocation proceedings would be considered. ... Purchasing of bullet proof vests is not considered [...] to be an expenditure on a charitable activity. ... It has not based its decision on each of these findings considered alternatively. ...

Armstrong's request for recognition of his 1993 rental loss could have been considered. Could the 1993 rental loss have been considered in the pending court proceedings? ... I see no reason in law or in principle why the Minister could not have considered Mr. ...