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In this appeal, there was evidence in the Western Motion that the auditor had considered one of the Refused Documents. ... There is no evidence that the document was prepared in the context of the audit of the Appellant or was considered by the CRA officials who had charge of the audit or was considered during that audit. ... Objection: There is no evidence that the document was considered by the auditor or CRA officials consulted with respect to the audit of the Appellant. ...

It is unclear whether the transaction being considered was carried out. ... The transactions considered in scenarios two and three are obviously permanent in nature. ... Before 1972, these capital outlays would have been considered "nothings". ...

(Emphasis added) [17] It is not in dispute that the appellant considered herself Mr. ... Cournoyer had feelings for each other during the periods at issue that could be considered feelings shared by common-law or married spouses. ... Cournoyer testified that he had always considered himself single, including when he filed his income tax returns. ...

A corporation the voting shares of which are distributed among a large number of persons is usually not considered to be controlled by any group of its shareholders, provided the shareholders do not act together to exercise control. ... In his reasons therein, Iacobucci J. summarized at paragraph 85 the principles of corporate and taxation law that are to be considered in determining whether there is de jure control: ¶ 85      It may be useful at this stage to summarize the principles of corporate and taxation law considered in this appeal, in light of their importance. ... Given that the hypothetical shareholder controls Sedona, the latter cannot be considered a CCPC. [29]     For these reasons, Sedona's appeal must be dismissed, with costs to the Respondent. ...

His practice also included property acquisitions in depressed real estate markets where he considered that the markets would eventually recover. ... Cassils was attracted to the Shopping Centre investment based on the projected returns, which he considered quite attractive. ... Poole was offered a 10 percent share, although he was interested in a larger investment since he considered 10 percent to be a minimal investment. ...

Iacobucci J. made it clear that external documents, other than the share register of the corporation, the articles of incorporation and unanimous shareholder agreements, generally should not be considered in assessing de jure control (paragraph 85). ... [Emphasis added.] [51]   Thus, the Federal Court of Appeal reiterated that the factors to be considered must arise from one or more legally binding agreements, again confirming that the criterion for analyzing control in fact is narrow. ... Various family and economic factors could therefore be considered, provided that these influence only the composition of the board of directors.” ...

Dirk is considered to have held insurable employment during the Relevant Period while working for both the Payer and BV. ... Therefore, this criteria was met since the worker is considered ordinarily resident of Canada. ... Also, it does not appear that the “work or report condition” was formally considered. ...

.: Rule 147(3) provides the factors to be considered in exercising the Court’s discretionary power. ... Justice Rothstein stated that these other factors provided guidance as to the type of matters that might be considered relevant in Rule 57.01(i).  At paragraph 24 of his Reasons, Justice Rothstein discussed what should be considered appropriate under Rule 57.01(1)(i): 24.  ...

However, where the activity could be considered a personal pursuit, then one must ask if the activity is being carried on in a sufficiently commercial manner so as to be a source of income. 19. ... Boles considered showing her dogs and horses a hobby during this time. ... What I considered, what I wanted for my own law practice which was tight monthly financial reporting. ...

The determination invokes reasonableness, suggesting that the possibility of different interpretations of the events must be objectively considered. ... Desmarais transferred only 41 of his shares of Comsercom, amounting to 9.78% of this company's shares, cannot be considered to have been concluded primarily for bona fide purposes, other than non-tax purposes. ... The specific anti-avoidance measure in former subsection 247(1) was no longer considered necessary because of the broad scope of the general anti-avoidance provision. [...] ...