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The taxation of benefits conferred from a trust was considered in this case, a decision of the Exchequer Court of Canada. ... The plaintiff suggests that the weight of previous authority shows that the granting of an interest-free or low interest loan to employees and shareholders was not considered to be a benefit to the taxpayer prior to the enactment of section 80.4 of the Act. ... Commissioner of Internal Revenue [465 U.S. 330] and found the reasoning of the Court to be interesting but by no means determinative, as it must be read in the light of the statutory enactment being considered by that Court. ...

In reaching his conclusion, he considered the financial position of Petrosar and other parties including: (a) the capital cost per annual pound capacity of Petrosar as compared to U.S. ... It was therefore argued that since the shares issued in payment of interest were valueless, the interest cannot be considered as having been paid. ... The expert witness Doak, as previously stated, considered in his valuation report this hypothetical option value” and attributed no value to it. ...

He would not embark on a new venture or expansion without first securing the expert and professional advice which he considered the best and base his decisions on that advice. ... He considered that he could not and he was not prepared to commit himself to an amount greater than $259,000, which includes $100,000 for renovations. ... He considered the highest use of the property to be that of an automobile dealership. ...

The Supreme Court of Canada, in Sinnott News Company, Limited v MNR, [1956] S.C.R. 433; [1956] CTC 81; 56 DTC 1047, considered a similar situation that arose at a different level of the distribution chain. ... [2] Sale of Goods Acts in 1969 were, in their effect, identical to those of the Ontario Act considered in the Sinnott News case. ... A case precisely similar to this case could have come from Scotland and your Lordships would then have considered the meaning of this phrase in Scots law. ...

As a result, the records could hardly be considered adequate such as would allow Mr. ... However, certain criteria must be satisfied before a housing unit can be considered a taxpayer's principal residence. ... I am not satisfied based on the evidence that Lot 224 can reasonably be considered Mr. ...

In reply to a question from the Court he said that he had prepared no adjustment chart in the present case as he considered that his other adjustments were affected by his time adjustment so he included them in it, merely concluding that the subject property might be ripe for development 10 years after 1971, while the others would be ready somewhat sooner. ... It was suggested in cross-examination that since he is in the employ of the Department of National Revenue he canhot be considered to be a neutral witness but I do not believe that his report should be rejected for that reason. ... A subdivision plan for a large lot residential development with internal public roads would be considered by the Township of North Dumfries and the Ontario Department of Municipal Affairs with lot sizes being a minimum of 15,000 square feet. ...

It was on that date that plaintiff acquired 835 shares and it was the market value of the shares on that date which is to be considered. ... It would be drawing too much from that passage to treat it as a considered interpretation dispositive of the present case. ... Pezim and Clemiss have been considered by the Court and a decision rendered concerning such claims. ...

Income earned on a reserve by an Indian is considered exempt. Income earned away from the reserve is taxable. ... Some of the types of income may be classified as follows: (i) Salary and wages are considered to be earned where the services are performed. ... The application of the connecting factors test to each defendant will be considered in turn. ...

But, as in the case of Acadia Saw Mills, where no such expenditures were made, the late filed designation was not to be considered as valid. ... Consequently, the designation in question cannot be considered to be filed as a valid designation in accordance with subsection 194(7) as the applicable penalty of $8,000 has not been remitted. ... Evidence at trial indicates that the letter of November 18 was not considered within Revenue Canada, Taxation as a Minister’s notice under the subsection. ...

The DNR considered that the assets used to transport raw materials and maintain the fleet of trucks were not used in qualified activities and that the salaries paid to employees involved in these activities included periods when they were not engaged in qualified activities. [4]      On January 22, 1988, Lomex objected to the reassessments issued by the DNR. ... The Queen, 95 D.T.C. 5026 (F.C.A.):      The Court of Appeal held that the mixing of various liquids or compounds when preparing a drug prescription is considered manufacturing and processing. However, the filling of prescriptions by placing labels on products already in their own container or by the placing of pills, capsules or liquids purchased in bulk into small containers and labelling them is not considered manufacturing and processing. 2.      ...