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She considered the bonus payments of about $4,000 were for working additional hours and was aware non-related employees did not receive any pay other than their regular wages or salary. ...   [8]      Counsel for the Respondent submitted the Appeals Officer properly considered the facts and weighed correctly the various indicia arising from the overall circumstances. ... The Minister considered this element not to be of any relevance since the business operated on a year-round basis. ...

Bower considered it superior to the subject property with respect to location. [32]     Mr. ... Udvari considered land only, not buildings, since the buildings were built for a specific use. ... Pyke adopted the cost approach since he considered it the stronger of the two approaches. ...

The Appellant stated she considered the status of her working relationship to have been complex. ... Clause 14.02 of the agreement states, “[T]he person who covers such absence shall not be considered an employee of the Corporation while performing such work.” ... That situation, as is common ground here, was that rural mail couriers were considered to be mail contractors and not postal employees. ...

Since that time, several cases have considered what it means for the parents of a qualified dependant to reside with the qualified dependant on an “equal or near equal basis.” ... Accordingly, there may be situations where non-numerical or unmeasurable factors should be considered in determining whether parents reside with a child on an equal or near equal basis. ... In endeavouring to confirm whether that was the situation, I have considered a number of approaches, five of which are summarized in paragraph 26 above. ...

In her view the permanent establishment would have considered purchasing the equipment, leasing it under a capital lease, or leasing under an operating lease. ... For this appraisal Svoboda utilized a cost approach and considered evidence based on sales of other similar assets to draw his conclusions. ... Nor should any allocated expenses be considered to bear a profit element for the portion of the legal entity that incurred the expenditure. ...

According to Penturn, Citroen is considered as "one of the leading lights of individuals in business in England". ... He considered the 20 per cent equity interest as his fee for “setting up the deal”. ... When he sold shares of Thornecliffe Park Ltd. from time to time, they were declared as capital dispositions; he did not know the reason he considered these dispositions on capital account. ...

The concept of allowance has been considered by the courts on a number of occasions, in particular in the context of paragraph (6)(l)(b) of the Act. ... The reimbursement of these expenses cannot be considered as conferring a benefit within the terms of the Act. ... As was stated above, four of the five Tax Court Judges who considered these five cases decided that the mortgage interest subsidy is not a taxable benefit. ...

The respondent points out that approximately 200 deposits were considered in the CRA’s deposit analysis, while the appellant has provided only 175 cheque stubs in support of his explanation. Thus, the respondent submits, at the very least there are 25 deposits for which no explanation has been given and those should be considered as unreported income of the appellant.   ... In its audit manual dated March 2008, the CRA states that the net worth method must be considered and used first unless it is impossible to obtain the information required in order to complete the net worth statement showing the evolution of the taxpayer’s assets and liabilities and personal living expenses over the relevant period. ...

Each of these will be considered below.     Statutory time limit      [23]          The respondent submits that the application to extend time was made on November 24, 2008, which is beyond the 15 month deadline imposed by s. 167(5)(a) of the Act ... The question remains as to whether any of the prior correspondence could properly be considered an application to extend time that was filed with the Court within the 15 month deadline ... If this interpretation is correct, then the letter could reasonably be considered to be an application to extend time to appeal ...

One might expect a person suddenly moved to make such a magnanimous donation to have at least considered other possible, and perhaps more worthy, donees. ... The Queen [2] and her statement in the first sentence of paragraph 18 where she said:             He is not part of a tax evasion scheme, and although he may have been motivated by potential tax benefits, I do not believe that this can be equated to consideration for a gift because tax benefits are not considered a benefit.... ... Justice Linden in Friedberg [3] to suggest that a scheme entered into whereby a person would be put in a position to claim tax credits for charitable donations in excess of the donations actually made, by the issuing of false receipts or by the kickback of part of the donation, to be a normal transaction and something that would not be considered a benefit within the context of the definition of what constitutes a gift. ...