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They are only indicia to be considered in order to determine whether such a relationship exists (paragraph 42). (27) Thus, in Quebec law, the criterion of direction and control remains the determining element (9041-6868 Québec, paragraph 12). ... The workers unanimously testified that they considered themselves self-employed workers. ... Meunier 's testimony is also very clear in this regard, that is to say that all workers were considered self-employed and not employees of the appellant. ...

The question before the Board was whether part of a disposition could be considered as capital account. ... The Department's position is that proceeds from all sales of livestock by a taxpayer in the business of farming, including those animals in a basic herd, are considered to be income. ... He suggested that the reason the word "livestock" alone was used, rather than “livestock inventory", was because of the difficulty with the fact that the livestock would not ordinarily be considered to be included in the inventory of the cash basis system of a farmer, "who would, in fact, have no inventory whatever" (TS, p. 118). ...

We considered other elements to support that inclusion of income. Mr. ... Chau: We considered-- yes, you’re right. We considered also explanation and justification from the taxpayer. ... The CRA decided to rely strictly on the explanation that they considered not credible and not satisfactory. ...

In the appellant’s view, the proper characterization of the disclosed facts could not be considered a misrepresentation. ... The Court believes that the Appellant in the present case would share the view that a filing position and the proper characterization of the disclosed facts cannot be considered a misrepresentation for the purposes of subparagraph 152(4)(a)(i) ITA. [37] In Mont-Bruno 2018, Justice Favreau considered a number of cases on misrepresentation. [17] Ultimately, Justice Favreau’s line of analysis suggests that this Court was not convinced that a filing position could not be a misrepresentation for the purposes of subparagraph 152(4)(a)(i) ITA. ... The fact is first disclosed, then considered and may lead to or support a conclusion of law. ...

I have identified below where I considered any such information useful ... For this purpose only one arm’s length transaction is considered, that involving McKesson Canada and TD Factors. ... That is, it was not that TDSI considered a 2.5 times multiple reasonable, it considered a 6 + times multiple reasonable but did not expressly say so ...

The Dunham Report considered the 10% interest rate paid on these loans to be excessive. ... Dunham considered these loans to be quasi equity that posed no financial risk to the company, whereas Mr.  ... What would be in the industry for the President of the company, my salary is considered low. ...

Canada. [3] [15]         In that decision the Supreme Court set out what constitutes “control” and what is to be considered in the course of determining whether someone has “control” of the corporation. ... I might add that I considered for this purpose whether Kruger controls the appellant’s pricing. ... The particular factors considered are in section 6.2.2 of the expert report, Exhibit A-7; the same report is also at Exhibit A-8 which attaches many supporting documents. ...

Professor Klein agreed that the size of the primary market for OTC currency options is considerable when transactions by all market participants are considered. ... It is difficult if not impossible to say that where only value is being considered in which a variable inheres you can have any other than a fluctuating estimate. ... Under s. 9(1), deductibility is ordinarily considered as it was by Thorson P. in Royal Trust, [Royal Trust Co. v. ...

Champagne in the course of his job in the economic crimes section and considered him an expert on paintings. ... The search was part of an investigation into what Revenue Canada considered a tax scheme. ... She considered the appearance and weight of the box, which was made of solid silver. ...

Travel to and from the employee's home and the place of employment is considered to be personal. ... However, he also considered the tests set out in Wiebe Door Services Ltd., supra, and determined that they were not conclusive either way. ... The Court agrees that that is a factor to be considered in the present case but it is not conclusive. ...