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As well, the activities of breaking bulk and repackaging are generally considered to be processing. ... M.N.R., [1982] C.T.C. 2076; 82 D.T.C. 1086, the cutting of fabric was not considered as “processing”. ... M.N.R., (supra) and one of the steps in their preparation consisted of packaging the vegetables, then the packaging activity would be considered “processing” even though it did not change it. ...

These rules provide that a taxpayer may not add the cost of a depreciable capital property to the relevant undepreciated capital cost (“ UCC ”) pool until the property is considered, under the Act, to have become available for use. ... The answer to this question determines the point in time at which the property is considered, for the purposes of subsection 13(26), to be available for use under the so-called two-year rolling start rule in paragraph 13(27)(b). ... Under subsection 13(27)(b), two actual year-ends must pass before a property is considered to have become available for use. [71] Under the Appellant’s position, the time is shortened by one actual year-end of the Limited Partnership. ...

Her daughter lived in New York City and she had considered moving to New York ... She also considered graduate studies in development work in an American or British university. ... Snow considered Vancouver as the place where she could "reconnect" and where, if she needed a place to stay, she could stay. ...

  [14]    The facts to be considered in a motion of this nature must show a continuing intention by an Appellant to pursue an appeal. ...   [15]    Another factor to be considered is whether or not the appeal has merit which discloses an arguable appeal. ...   [17]    Finally, one factor that must be considered is whether a reasonable explanation is given for the delay. ...

  [1]               The appellant is appealing a decision by the Minister of National Revenue (the Minister) according to which: (1) she did not hold insurable employment from August 31, 2006, to August 31, 2008, and (2) the amounts she received for lost wages and loss of employment were a retiring allowance within the meaning of the Employment Insurance Act (EIA) and the Insurable Earnings and Collection of Premiums Regulations (Regulations), which is not considered insurable earnings ... The $42,000 paid by Iris was a retiring allowance within the meaning of paragraph 1(1)(b) of the Regulations, which is not considered insurable earnings under paragraph 2(3)(b) of the Regulations. ... Such an amount is in keeping with the definition of retiring allowance, which is not considered insurable earnings. ...

Eaton, given the circumstances of your appeal, not in the sense of personal circumstances and the extent to which you have felt victimized, not only a victim of gender discrimination in pay, but in terms of the entire process and the representation that you have had, notwithstanding my sympathy for those issues, I want you to know that, in all of the circumstances, given the state of the law, that you made a reasonable case this morning, that is, one that actually caused me to consider whether or not your appeal can be considered in a different light than the appeals that have already been heard by this Court. ... I will deal only with two of those arguments as, in my view, only those two could be considered relevant to the jurisdiction of this Court.  ... It is for retroactive pay awarded under the authority of paragraph 53(2)(c) of the Canadian Human Rights Act, which provides for any or all wages a victim is deprived of, as considered proper by the Tribunal. ...

": "To be considered a newly constructed residential complex, the addition must at least double the size of the habitable area of the existing residence." The Bulletin states that an added garage does not count because it is not considered a "habitable" area. ... In my opinion, this is still not sufficient for it to be considered that all or substantially all of the building was renovated or replaced. ...

ANALYSIS: [14]     Sections 256(5.1) of the Act reads as follows: (5.1)      For the purposes of this Act, where the expression "controlled, directly or indirectly in any manner whatever," is used, a corporation shall be considered to be so controlled by another corporation, person or group of persons (in this subsection referred to as the "controller") at any time where, at that time, the controller has any direct or indirect influence that, if exercised, would result in control in fact of the corporation, except that, where the corporation and the controller are dealing with each other at arm's length and the influence is derived from a franchise, licence, lease, distribution, supply or management agreement or other similar agreement or arrangement, the main purpose of which is to govern the relationship between the corporation and the controller regarding the manner in which a business carried on by the corporation is to be conducted, the corporation shall not be considered to be controlled, directly or indirectly in any manner whatever, by the controller by reason only of that agreement or arrangement. [15]     The question of " de facto control" has been considered by Canadian Courts on a number of occasions. ... However, whatever factors are considered, they must show that a person or group of persons has the clear right and ability to change the board of directors of the corporation in question or to influence in a very direct way the shareholders who would otherwise have the ability to elect the board of directors (Silicon Graphics, [2002 DTC 7112] [2002] FCA 260, para. [67]). ... The Queen, 2002 DTC 7112, the Federal Court of Appeal also considered " de facto control". ...

I am not at all convinced that the appellant seriously considered that his farming losses and his losses as an author were from the same activities. ... The appellant’s principal income from giving riding lessons in the years under review cannot objectively be considered as a business. ... If giving riding lessons can be considered as farming (I have serious doubts that it can) it cannot, in my opinion, be considered as a sideline business, because it did not have an objective and reasonable expectation of profit. ...

Exhibit R-l is a description made by Counsel for the Respondent showing what are considered to be capital expenses for the Hinton properties. ... The estate is considered the owner of the properties. However, it does not report the rental income. ... It surely cannot be said because a person operates a rental business consisting of several properties that these properties will not be individually considered. ...