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It reads: (1) For the purposes of subsection 6(16), sections 118.2 and 118.3 and this subsection, (a) an impairment is prolonged where it has lasted, or can reasonably be expected to last, for a continuous period of at least 12 months; (b) an individual's ability to perform a basic activity of daily living is markedly restricted only where all or substantially all of the time, even with therapy and the use of appropriate devices and medication, the individual is blind or is unable (or requires an inordinate amount of time) to perform a basic activity of daily living; (c) a basic activity of daily living in relation to an individual means (i) perceiving, thinking and remembering (ii) feeding and dressing oneself (iii) speaking so as to be understood, in a quiet setting, by another person familiar with the individual, (iv) hearing so as to understand, in a quiet setting, another person familiar with the individual, (v) eliminating (bowel or bladder functions), or (vi) walking; and (d) for greater certainty, no other activity, including working, housekeeping or a social or recreational activity, shall be considered as a basic activity of daily living. 7 The Appellant's impairments in 1993 relate to elimination and walking. 8 He wore a catheter. ...

Section 118.4 reads as follows: 118.4(1) For the purposes of subsection 6(16), sections 118.2 and 118.3 and this subsection, (a) an impairment is prolonged where it has lasted, or can reasonably be expected to last, for a continuous period of at least 12 months; (b) an individual’s ability to perform a basic activity of daily living is markedly restricted only where all or substantially all of the time, even with therapy and the use of appropriate devices and medication, the individual is blind or is unable (or requires an inordinate amount of time) to perform a basic activity of daily living; (c) a basic activity of daily living in relation to an individual means (i) perceiving, thinking and remembering, (ii) feeding and dressing oneself, (iii) speaking so as to be understood, in a quiet setting, by another person familiar with the individual, (iv) hearing so as to understand, in a quiet setting, another person familiar with the individual, (v) eliminating (bowel or bladder functions), or (vi) walking; and (d) for greater certainty, no other activity, including working, housekeeping or a social or recreational activity, shall be considered as a basic activity of daily living. ...

Gall considered his role similar to that of a franchisee. While he operates within the Knights of Columbus’ guidelines he runs his business his way for himself but not by himself. ... That screening, whatever the result, cannot be considered routine approval ... I agree that one’s home would not normally be considered a place of business if only a minor amount of business activities occur in the home. ...

Régent Blouin, counsel, wrote to the tax authorities on November 5, 2002, to inform them of the Appellant's position and state the reasons it considered the assessment to be incorrect; (add letter)   31.       ... Results   §         The amount of the advance received by Mary is not considered as employment income. ...  -          If the advances are more than the amount of the award, the difference is considered employment income. ...

The question then becomes whether the transaction(s) may reasonably be considered to have been undertaken or arranged primarily for a bona fide purpose other than to obtain a tax benefit ... The Appellant also argued that the Redemption is irrelevant to a determination of whether the 1993 Share Sale and First Amalgamation have bona fide non-tax purposes because the First Series of Transactions have to be considered alone in ascertaining whether the primary purpose was to achieve a tax benefit ... Canada, 2007 DTC 5172, 2007 FCA 113, the Federal Court of Appeal confirmed that the overall purpose of the series of transactions must be considered in understanding an abuse analysis. ...

Langdon, or any of their associates, would have considered it to have any value at all. ... It did not contain the words "may reasonably be considered that... ... Again, subsection (4) did not have to be considered. [61]          In OSFC Holdings Ltd. v. ...

For tax purposes, such remuneration is considered sourced where the training took place and should be allocated on the basis of working days. ... As a result, they are considered taxable to the extent the other services that you provide to Air Canada are performed in Canada. ... The only relevant factor to be considered is whether the remuneration is attributable to duties performed in Canada. ...

This disposition was considered to be a gift of property by the Appellant to the Class “B” shareholders. 5. ... Martin considered that the Class B common shares would not be subject to any material minority discount as of August 28, 1989. ... The same fact was not considered to be an important factor by Mr. Martin in establishing the value of the Class B common shares after the Special Resolution. ...

This project is considered as qualifying under section 2900(1) of the Income Tax Regulations. ... This project is therefore considered as qualifying under subsection 2900(1) of the Income Tax Regulations. ... Rompré indicated that he considered the findings of research conducted on an experimental farm in ideal conditions to be less convincing. ...

If the answer to the first question is yes, may the transaction, or transactions, reasonably be considered to have been undertaken or arranged primarily for bona fide purposes other than to obtain the tax benefit? ... It did not contain the words “may reasonably be considered that...” This Court, for purposes of decision, assumed, without finding, that the test was subjective. ... It simply purchased a partnership interest on what it considered to be, and ultimately proved to be, commercially advantageous terms. 4. ...