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There was no reason, apart from his residence, for the respondent to be in England except when in his own discretion he considered that the English subsidiary company required supervision. ... In paragraph 30 of Interpretation Bulletin 270-R we read: 30. the territorial source of income from an office or employment is considered to be the place where the related duties are normally performed. ... Director's fees are generally considered to be earned where the director's meetings are held and commission income is earned in the country in which the effort was expended for the purposes of gaining such remuneration. ...

Before a bonus can be considered as an integral part of salary and a deductible expense, it must, in my view, meet certain criteria. ... However, I disagree with counsel's argument in this assumption that because some amounts were paid by cheque to the shareholder account, those payments should not be considered as "amounts paid” (see Exhibit A-10). ... In that decision, the Court provided certain interpretative guidelines (see pages 316-17 (D.T.C. 6323-24)) as to what transactions should be considered inoperative on the basis of their artificiality. ...

The amount, if any, that is considered to be reasonable must be based on the facts of each particular case. ... It would not be considered reasonable for a shareholder who provides no services to the corporation in which he holds shares to receive a Salary. 3. ... Weiler's first alternative cannot be considered, seriously or otherwise. ...

These clocks and scoreboards display the various logos of the company's products and are considered to be a useful advertising tool which triggers an impulse to buy these products. ... As counsel for the Minister pointed out, this issue has already been considered by the Tax Review Board in Browning Harvey Limited v. ... It is only under quite exceptional or unusual circumstances that such an operation should be considered as a speculation. ...

Davis, Q.C. described at page 1137 (D.T.C. 768) of the report the changes made to a beverage room: The second item to be considered deals with a number of changes, some of a structural nature, made to the hotel premises upon the suggestion or recommendation of the Alberta Liquor Control Board. ... M.N.R., [1963] C.T.C. 116; 63 D.T.C. 1075, that the matter must be considered from the viewpoint of both the purchaser and vendor, taking into account all relevant circumstances surrounding the transaction. ... It was the allocation deliberately chosen by the appellant as representing the value of each item sold, one which he considered reasonable. ...

Subsection 31(1),which is substantially the same as that considered in the Moldowan case (supra), reads in part Where a taxpayer's chief source of income for a taxation year is neither farming nor a combination of farming and some other source of income... ... Among those factors considered by the trial judge were: (i) the plaintiff had always desired to return to farming and geared his employment to the ultimate achievement of that objective. ... Many cases have concluded that where from the very commencement of farm operations a considerable loss has occurred every year, the farming operations could not be considered a source of income combining with other sources to form a chief source of income. ...

He considered his knowledge of science to be invaluable and believed that his continuing quest for additional knowledge made him adept in the learning process. ... It is not clear whether the possibility of reduced crops or crop losses due to excessive moisture in wet years was considered in his projections. ... All of the foregoing factors have been considered and weighed. Without doubt there was an intellectual commitment to farming. ...

It appears from these latter documents that Leaside considered the subject property as inventory in the balance sheet. ... Learned counsel for the defendant agrees that book-keeping, by itself, is not conclusive, but is still an element to be considered. ... This decision is confirmed by other elements which are not conclusive by themselves but must be considered in the present circumstances: (a) The president of the appellant, Mr. ...

Which items properly qualified as “soft costs/' and therefore deductible, and which should be considered as capital items? ... The “matching principle” does not apply and can be considered as an expense when incurred. Inasmuch as that time was before the date of the joint venture agreement and all investors undertook to pay the amount, it is considered as a cost of acquisition. ...

On the other hand, for a taxpayer to be considered in business, he must be actively involved with and be a participant directly or indirectly in the income-producing processes of the business. ... Put another way, the appellant claimed that he can be considered as carrying on the horse business only if he was a partner with the other co-owners — if he was not a partner then, according to the appellant, he was not carrying on any business. ... Unlike MURBs and other assets such as bonds debentures, etc, which by their very nature are income-producing with a minimal amount of effort and activity, race horses by themselves can only produce income as a result of constant care, maintenance, training and grooming, to the point where they cannot, in my view, be considered as self-generating income property. ...