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He considered "going public" by contacting the press and electronic media to explain the unfair treatment of FBL. ... In an agarian society, land is considered to be the source of income. ... Cameron J. considered the cases such as J. Gliksten and Son, Limited v. ...

Accordingly, during the audit, the CRA considered the purpose of individual transactions but only in the context of determining the purpose of the series. ... The determination invokes reasonableness, suggesting that the possibility of different interpretations of the events must be objectively considered. ...   [86]          It is considered that the Minister is in a better position than the taxpayer to make submissions as to the object and spirit of legislative provisions. ...

The US$8,000 withdrawal was considered a payment for the condominium. [23]     Exhibit A-3 is the purchase contract for the condominium. ... However, the reduction of $8,515 already allowed him must be considered. ... I could have considered awarding only some of the costs to the respondent. ...

Overvelde said that he considered that this settlement had a certain influence on the operation of the company. ... M.N.R., 66 DTC 5280 and more specifically to that part of the decision where Martland J. considered the decision of Duff J. in the case of M.N.R. v. ... Changing the share structure by eliminating dissident shareholders cannot be considered to be part of the income earning process of the business. ...

“No charge parking” has never been considered by them to be a benefit. ... Canada, [1996] 2 C.T.C. 33 (FCA), the question of whether the advantage accrued primarily to the employer or the worker was considered. ...   [134]      The question of valuation was considered in the case of Schutz v. ...

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 other workers – considered to be independent contractors were issued Summary of Contract Payments forms (T5018s), filed as Exhibit A-6 ... Although Tsakalos and Hoy and Belos testified they all considered it was possible for a worker to hire a helper, that event never occurred. ... He considered himself to be an independent contractor and had provided his services to Marathon in 1999 and 2000 on that basis. ...

If the primary purpose of any transaction is to obtain a tax benefit it is considered an "avoidance transaction". ... Further, the nature of the business aspect of the transaction must be carefully considered. ... Whether it may reasonably be considered that any of the avoidance transactions would result in an abuse of the Act?                 ...

These workers were paid an hourly wage and an individual fulfilling the role of Sales Coordinator was considered to be an independent contractor. ... Klassen stated she then considered the remuneration paid, the terms and conditions, the duration and nature and importance of the work performed prior to making the ruling. ... Klassen and Klassen stated she considered the duration of the employment and found RAF operated year-round. ...

Intention of the Different Persons Involved [48]         It is clear from the testimony of Paule Grenier and Susan Bell that the company considered the teachers to be self‑employed. [15] [49]         Janice Walsh-Bonal and Mark Miller testified that they considered themselves self‑employed. They filed their income tax returns on the basis that they were self‑employed, and they claimed expenses. [50]         According to the assumptions of the Minister, six other teachers considered themselves self‑employed while one, Christine Bisaillon, was not sure of her status. [51]         Again, according to the Minister’s assumptions, André Beauregard and Marika Andrassi considered themselves to be employees. [52]         Finally, in the case of Dalia El Mourad, she testified that she did not understand the contract. [53]         She also testified that she considered herself to be an employee. ... Liza Rumjahn, Michael Dawson, Judith Gostick and Janice Walsh‑Bonal all considered that they were independent contractors. ...