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Cardinal considered them as being of a training nature and the costs related thereto were claimed as current business expenses. ... Expenses are considered to be capital in nature where the training results in a lasting benefit to the taxpayer, i.e. where a new skill or qualification is acquired. Where, on the other hand, the training is taken merely to maintain, update or upgrade an already existing skill or qualification, the related costs are not considered to be capital in nature. ...

It was the taxpayer’s election and there was no basis upon which the Minister, absent legislative authority, could be allowed to impose the choice on him even if the taxpayer considered it beneficial. ... This was obviously a factor to be considered in interpreting Parliament’s intention. ... There are also other factors that may be considered with regard to making an election or a designation at the time of a reassessment, including the prejudice caused to the rights of the Minister or other taxpayers. ...

The phrase "adventure or concern in the nature of trade" was considered by the Exchequer Court of Canada in M.N.R. v. ... " To determine what is "ordinary" in an isolated transaction the event being set in motion must be one that is considered ordinary in trade. If the isolated transaction is in the nature or concern of a particular trade, the transaction ought to be a transaction considered ordinary in that trade. ...

On the other hand, the respondent considered the appellant present in Canada for a day if he spent any part of that day in Canada ... Deputy Attorney General of Canada                                                           Ottawa, Ontario [1]               In his notice of appeal the appellant raised other issues that were not considered in evidence nor in argument at trial and are therefore not considered in these reasons. [2]               Much of the appellant's evidence was to establish that he was resident in the Bahamas. ... It was difficult to determine if he was in Canada on certain days because of the colouring on the calendar or the legibility of the writing; in such cases I considered Mr. ...

It is considered to be "one of the nicest farm in the valley." Most of the work was completed by 1991. [10] The breeding barn included good ventilation, stall frames and was considered to be safe to prevent the horses from escaping and injuring themselves. ... He considered himself to be in the general practice of dentistry and does a lot of denture work. ... He worked six to seven hours a day and considered that to be a normal dentist's practice hours. ...

No authority is cited for the statement that costs can only be considered from the time litigation is initiated. [30]          In Murano et al v. ... It went on to say that factors considered by Revenue Canada included efforts shown to reduce costs and turn a profit and devotion of time to the operation. ... " He also said: "Costs can only be considered from the time litigation is initiated. ...

A creditor acting reasonably and honestly, must be given some latitude in determining the year in which a debt should first be considered to be a bad debt. ... The prudence of the creditor as a reasonable businessperson in making the determination might be considered as a means of objectifying a determination that might otherwise inappropriately accelerate a loss claim. ... The question of when a debt is to be considered uncollectible is a matter of the taxpayer's own judgment as a prudent businessman. ...

The classic rule is that evidence may be adduced of foreign law which is considered a fact but not of domestic law. ... Whether the CRA considered applying GAAR or considered applying any other section of the Act that is not referred to in the pleadings is not relevant. ... The questions and answers related to whether the CRA considered applying GAAR are not admissible ...

However, if that was the reason for the Appellant declaring the advances as bad, how can he be said to have personally considered at that time the relevant factors required to be considered in making an honest and reasonable determination as whether the debt was bad?   ... The evidence confirms that the repayment of the loans was not considered, let alone analyzed, in this way. ...   [13] I have considered several possible scenarios including: Scenario 1. ...

Canada (Minister of National Revenue), [4] I considered the meaning of the word “from” in the context of a different issue that arose under the Canada Pension Plan (CPP). ... One such argument I have considered is the drafter’s use of the word “from” as opposed to “for” in subparagraph 115(1)(a)(i). ... It would be exceptional to find that the QPP payments were considered pension payments under the Act and not considered pension payments under a treaty. ...