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Kam-Press acknowledges that the definition of SR&ED applicable in 2009 and 2010 is not materially different from the definition that was considered in Northwest Hydraulics. [6] In its memorandum, Kam-Press does not acknowledge that this Court considered and approved the approach as set out in Northwest Hydraulics. ...

The criteria enunciated in IT-419 have also been the criteria consistently considered by the courts. ... While the plaintiff stated that it did have replacement in mind should the plaintiff ever lose the services of Peter Cundill, it is clear that they considered him to be among the best, if not the best, investment counsellor in the field and that replacing him would have been a source of great disruption to the plaintiff's affairs. ...

Thus, we have considered the appellant’s appeal on the basis of the Appeal Book filed before the Court. [3] In the present case, the applicable standard for questions of law is correctness and the applicable standard for questions of mixed fact and law is palpable and overriding error (Housen v. ... Dow Chemical Company, 2016 FCA 216, 487 N.R. 230 at para. 14). [7] The appellant suggests that the Tax Court judge considered him dishonest. ...

The periodical in question falls under clause (E) of subparagraph (5)(a)(ii) of section 19 of the Act and accordingly it is to be considered “non-Canadian” within the meaning of subsection 19(1). ... The learned and distinguished Associate Chief Justice, in his reasons for judgment, said: Indeed, if the calibre of the people who have written these articles, as well as most of the articles themselves, are considered, this publication must be accepted as a vehicle for the dissemination of scholarship in a field which, until recently, was one that had never been properly treated by doctors. ...

Multiple factors, sometimes subjective and impressionistic, fall to be considered. ... The Minister considered those submissions. Nothing in the circumstances of this case suggests that the Minister had to seek further information, documents or submissions from the Appellant. [10] We observe that the Federal Court closed its whole hearing to the public. ...

No other connecting factor was suggested by the parties or considered by the Trial Judge. [21]            Given the importance of the location of the employer as a connecting factor, the Trial Judge concluded that Ms. ... In Williams, an unemployment insurance case, the location of the qualifying employment was considered to be an important factor in establishing whether subsequent unemployment insurance benefits would erode the entitlement of an Indian qua Indian on a reserve. ... For example, it is not clear how the respondent's dignity would be affronted if her residency off-reserve were considered in a connecting factors analysis. ...

Creditor protection, in their submission, should be considered as a relevant factor in determining the reasonableness of the allocation of income for the purposes of subsection 103(1.1) of the Act. [5] For the reasons that follow, I would dismiss these appeals. [6] These appeals were consolidated, with A-313-19 as the lead appeal. ... To determine whether the allocation in issue in this case was reasonable in the circumstances, the Tax Court Judge considered whether arm’s-length parties would agree upon this particular allocation of income. [16] The Tax Court Judge noted that the allocation of income to the four family trusts did not reflect their capital contribution or the work performed by these trusts. ... Consideration of What Partners Dealing at Arm’s Length Would Do [28] The crux of this case is what should be considered in deciding whether an allocation of income is “reasonable in the circumstances having regard to […] such other factors as may be relevant”. ...

The one that did show something significant was considered to be encouraging although still relatively modest. ... The understanding was that he would prospect in an area that he considered promising and report to the appellant. ... The meaning of these words was considered by the Supreme Court of Canada in Appleby v MNR, [1975] 2 S.C.R. 805; [1974] CTC 693; 74 DTC 6514. ...

To that end, it first considered whether the goods fell under heading No. 63.07. ... This means that while textile materials of Section XI are not to be considered plastics within the meaning of heading Nos. 39.01 to 39.14, the converse is not necessarily true, as plastic materials of Chapter 39 could possibly be considered textiles within the meaning of Section XI. ... There are no indications before the Court that such avenues were considered by the respondent. ...

I conclude from the evidence that the $500 given by Mr Beïque to his wife in 1940, to buy a piece of land adjoining the family home, must be considered, pursuant to subsection 21(1) of the Income Tax Act, with the contribution of $1,000 which Mrs Be'I'que had made the previous year, the year they were married, to buy for her husband the piece of land on which this house was built. ...