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Al Saady was cross-examined on his affidavit and explained why the Respondent believed that it was acting in compliance with the Production Order when it made the disclosure, and specifically, why the Respondent considered the foreign currency transactions to be “transfers of funds” and thus encompassed by the Production Order. ...

The Applicant has referred the Court to portions the SWAP Guide, which identify the circumstances in which a seasonal worker is considered a resident, non-resident, or deemed non-resident of Canada for tax purposes. ...

(a) Any reference herein or in the Laws to “old age pension” and “old age pension fund” is descriptive only, and not to be considered as an admission by the Plaintiff as to the existence of a pension plan for member of the ITU. ...

It was considered by Scurry Rainbow Oil Limited to be a desirable property which it sought to acquire and did acquire. ...

Subsection 120(1) of the former Income Tax Act, which is similar to subsection 52(6) of the Excise Tax Act, was considered in those two decisions, but the facts and the problems were quite different from the matter before me. ...

The Minister disallowed the deductions on the ground that the said loss to the partnership was considered to be a capital loss. ...

He also referred to the statement of Rowland, J at an earlier stage in the same case ([1930] 1 KB 279 at 284) when, in referring it back to the Commissioners, he stated: I do not indicate which way it ought to be, but I commend the Commissioners to consider what took place in the nature of organizing the speculation, maturing the property, and disposing of the property, and when they have considered all that, to say whether they think it was an adventure in the nature of trade or not. ...

Previously Mr Mockler said in effect that when discussing the situation with Mr Levine he indicated concern about there being relative equality among his four sons and he acknowledged that each had worked with him and each had contributed to the growth of the enterprises and he indicated he considered it an obligation to see that they were equally treated. ...

Mr Levitt and Mr Abrams candidly admitted that they knew of the tax savings but as above stated they considered such savings to be “merely incidental” to the overall advantages in their plan. ...

Under the trustee agreements, the trustees were authorized to invest in any security which they considered advisable. ...