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No system of keeping track of the renovation expenses was in place or even considered. ... It was most apparent from his testimony that he considered Ljubisav his benefactor and would do whatever Ljubisav asked without question. ... I further find that even if the appellant was not specifically aware of the existence of the unregistered deed, the ultimate transfer to her could not in any sense of the word be considered a gift. ...

Paquin then stopped to establish the optimum use of the lot, which he considered to be [Translation] "naturally destined for a major commercial use" (Exhibit A-1, p. 12). ... Among the factors to be considered, his report mentions [Translation] “the transaction date, the location of the pieces of land vis-a-vis the subject, their shapes and dimensions, and other special features regarding certain of those sales (Exhibit A-1. p. 14). ... Paquin concludes that there was an average rise of 1.6 per cent per month, which he considered more realistic over the period in question when Laval was experiencing accelerated growth. ...

Business Loss or Business Investment Loss Issue Before dealing with the specifics of the present appeal, there are certain principles to be considered in cases such as this. ... The principal factor to be considered is whether or not he acquired the shares as an investment or a trading asset. ... Justice Pigeon said that it is obvious that a loan made by a person who is not in the business of lending money is ordinarily to be considered as an investment. ...

Single purpose entities normally record municipal levies as an expense because such fees do not create any physical improvement to the land and are generally considered to be a cost of earning rental revenue. ... Both of the foregoing approaches can be considered to be Generally Accepted Accounting Principles. ... And finally, I think that an accounting expert should have at least considered the possibility of capitalizing the $214,848 as a pre-construction building cost but Mr. ...

This proposal contained the following provision respecting the equipment used on the site: All items whose new replacement value per unit, including taxes, is in excess of $700 shall be considered as equipment. ... The 2 percent is considered to be 1 percent for shipping to the site and maintenance and 1 percent for the cost of money. ... Power will purchase all DUJV equipment on site now or which may come on site except equipment which may be considered to be short term rental equipment, with the cost to N.B. ...

I am satisfied that the agreement detailed therein was that which the parties considered in effect as of November 1, 1982. ... I am equally satisfied in the capacity of an "independent contractor" they should at least be considered. ... To formulate a decision then, the overall evidence must be considered taking into account those of the tests which may be applicable and giving to all the evidence the weight which the circumstances may dictate. ...

There is no reason why any income earned by it should not be considered as prima facie income from a business so long as it is recognized that the presumption is a rebuttable one. ... In arriving at this conclusion the Court has considered the decision rendered in The Queen v. ... The Court has also considered the decision rendered in Massey-Ferguson Ltd. v. ...

Therefore, the amount of $550,000 identified by your client can be considered the target amount, but should not be considered the exact amount that your client will receive. ... Items to which our counter-offer does not respond, if any, are against the law and should not be considered. [17] On March 13, 2019, counsel for the respondent emailed a letter providing a detailed explanation of the respondent's revised proposal, which included the following: [translation] Our clients' joint proposal, dated February 27, 2019, suggest adjustments to the assessments in dispute that would result in an estimated $549,186.63 prepayment....... ... These last two requests from your clients run counter to applicable laws and public order and should therefore not be considered as part of the essential component of your February 21, 2019, offer. ...

For the purposes of this section and section 53, where a taxpayer, other than a broker or dealer in securities, is a member of a partnership and an amount is designated by a corporation under subsection 194(4) in respect of a share, debt obligation or right acquired by the partnership in a taxation year of the partnership where the partnership is the first person, other than a broker or dealer in securities, to be a registered holder of the share or debt obligation or to have acquired the right, as the case may be, such portion of that amount as may reasonably be considered to be the taxpayer’s share thereof shall be deemed to be an amount designated on the last day of that year by the corporation under subsection 194(4) in respect of a share, debt obligation or right, as the case may be, acquired by the taxpayer on that day where the taxpayer is the first person, other than a broker or dealer in securities, to be a registered holder of the share or debt obligation or to have acquired the right, as the case may be. ... First, BSCT is considered to have acquired the SRTC instrument on the last day of the partnership’s taxation year, being December 30, 1986 and second, it is deemed to be the first holder of the SRTC instrument. ... This issue was neither canvassed or considered by the Federal Court of Appeal. 10 Agreed Statement of Facts, paragraphs 6, 7, 9, 10, 11 and 12. 11 Exhibit A-l, paragraph 8. 12 Exhibit A-1, paragraph 9. 13 Exhibit A-l, paragraph 13. 14 Exhibit A-2, Tabs 6 and 8. ...

This is her stated intention and such must, of course, be considered by the Court. ... HMQ, 2018 TCC 258, Justice Bocock of this Court set out a list of indicia to be considered in determining occupancy. ... I do not know if any of these options were affordable, could practically have been carried out or if they were even considered. ...