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The other payments were considered as income (Exhibits 1-19, page 16, and I-9, page 20). ... This means that the appellant considered it an investment. In 1990, he decided not to be repaid, to make a donation. ... Furthermore, can the outlays made with respect to Prodimpex be considered an investment? ...

Beneficiaries are considered actual beneficiaries only from the time of entitlement to endowments. ... Sommerer should not be considered the "person".   [109]      Having said that I still conclude that, if Mr. ... The following in particular are considered important reasons: 1.       ...

Demers should have considered the tax credits arising from an SR&ED application. ... Demers, meanwhile, considered a single adjustment amount of $400,000. ... As for the respondent, she considered a range corresponding to 40% to 50% of expenses incurred for new product development. ...

(4)         Should embedded income taxes be considered in determining the fair market value of the shares of Holdco? ... Mr. de Gray said that, generally, minority and marketability discount would be considered together. ... Spencer testified that he considered using the RCGT Statements, but he did not use them because the Internal Statements were available. ...

He explained that the Program provided “additional leverage” for his charitable giving but would not have considered a bank loan for such a purpose. ... The Queen, 2018 TCC 66 (“ Markou TCC ”), Justice Paris also considered a leveraged donation program. ... All of the Appellants indicated that they understood this. [148] It was also clear from their testimony, that the Appellants would not have considered applying for a loan from a conventional lending institution for the purpose of making a donation. ...

  [212]      This point was considered by the Federal Court of Appeal in Hammill v. ... It is an economically relevant fact that should have been considered by Mr.  ... CASES CONSIDERED   Canadian cases   Apa v. The Queen, 2004 DTC 2365 (TCC).   ...

This factor has also been considered in subsequent investment income cases:  see, e.g., Lewin v. ... While it is true that the contract in this case was signed on the reserve, this factor cannot be considered significant, since the debtor’s place of residence was also on the reserve ... The judgment of the Court was delivered by Linden J.A. who analyzed the connecting factors considered in Williams.  ...

However, it is far from certain that a partnership can always be considered as operating a business within the narrower sense of the Act. ... It must be borne in mind that a partnership is not considered as having separate legal personality either in common law or in civil law. ... I have also considered the decision by my colleague Judge Bowman in Allen v. ...

Weatherby considered that these two tracts of land had a per acre similar value. ... Weatherby's report was considered by him to be the upper limit of value benchmark. ... The sales that the latter considered extended over a ten-year period, from 1965 to 1976. ...

Hejazi’s evidence after I have considered the evidence of the Respondent’s expert ... McCann then considered private market sales by the Appellant and her spouse. ... McCann considered certain jurisprudence relating to the valuation of shares ...