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Justice Campbell Miller was of the view that the charity’s address as indicated on the official receipt could not be considered as the place of issuance of the receipt. ... The receipts being considered here must show not only the address of the organization as recorded with the Minister, as required by paragraph 3501(1)(a) of the Regulations, they must also show the place or locality where the receipts were issued as required by paragraph 3501(1)(d). ... The purpose of this first stage of the test is simply to distinguish between commercial and personal activities, …  [W]here the nature of a taxpayer’s venture contains elements which suggest that it could be considered a hobby or other personal pursuit, but the venture is undertaken in a sufficiently commercial manner, the venture will be considered a source of income for the purposes of the Act.  53 ...

It is also the case that the parties’ mutual intention or stipulation as to the nature of their contractual relations should be considered and may prove to be a helpful tool in interpreting the nature of the contract for purposes of characterizing it under the Civil Code. ... Canada, 2009 FCA 47, 2009 DTC 5056, wherein the intention of the parties is described as an important factor to be considered in characterizing a contract for purposes of the Civil Code. ... Conclusion [36]          Having considered all of the relevant facts as they relate to the parties’ intention and the indicia or considerations of subordination and control, tools and supplies, and financial risk and opportunity, I conclude that the relationship between Ms.  ...

Keshmiri works as a millwright and industrial electrician and was clear in stating that he considered himself to be self-employed. [19]   He currently has a registered company and issues invoices through his company, [20] but this company did not exist when he was working with European Staffing. [10]   Mr. ... Pajecki did not understand what it meant to be a subcontractor and considered himself to be an employee. [48] He testified as follows: “That time I need a job. ... Kenny testified that he was never told that European Staffing considered him to be a contractor until he sought his record of employment from them following his being laid-off. [115]   Ms. ...

Fawzi testified that he considered himself an employee despite the fact that he had executed a Subcontractor Service Agreement which indicated that he was a subcontractor. ... M.N.R., 2001 CanLII 66 (TCC) [Goodale], Justice Porter considered a factually similar situation; however, the level of control exerted over the workers in that case exceeds the level of control in this case. ... The evidence has shown that the Workers understood the benefits and risks of being self-employed and that the intent of both parties to the relationship indicated that the Workers wanted to be considered as independent contractors; the economic reality of their businesses may not rise to a high level of entrepreneurial sophistication, but this fact alone should not derogate from their ability to contract freely as they choose simply because of the limited scale of their businesses. ...

Even though the teachers were considered to be independent contractors, they did not charge the school any GST/HST. ... As a result, Royal Winnipeg Ballet stands for the proposition that what must first be considered is whether there is a mutual understanding or common intention between the parties regarding their relationship. ... As noted in Royal Winnipeg Ballet at para. 64, the relevant factors must be considered “in the light of” the parties’ intent. ...

Those sections read as follows: 10 The law shall be considered as always speaking, and where a matter or thing is expressed in the present tense, it shall be applied to the circumstances as they arise, so that effect may be given to the enactment according to its true spirit, intent and meaning. … 12 Every enactment is deemed remedial, and shall be given such fair, large and liberal construction and interpretation as best ensures the attainment of its objects ... In addition other factors must be considered in the context of the scheme of the Informal Procedure as set out by the Act and the Informal Procedure Rules. ... Such an interpretation is inconsistent with a purposeful interpretation of the Tariff. [29] To give an example of a similar nature if parties do the work necessary to file a written agreement on part of the facts saving two days of trial, one might reasonable adjust for that taking the Tariff into account. [30] In so doing I have considered the following: There were two Appellants and two Notices of Appeal had to be filed; this amounts to two times $185, $370, under the Tariff. ...

Having considered the balance of $53,247 as an eligible capital expenditure, it claimed the sum of $2,576 under paragraph 20(1)(b) of the Income Tax Act, R.S.C. 1952, c. 148 (am. ... The interpretation that appears from these three decisions is that an expense may not be considered to be made for the purpose of earning income from a business if it is a capital expenditure. ... Those expenses were considered as a capital outlay contemplated by the exception of paragraph 12(1)(b) of the Act of 1952. ...

The fact that the commission on a car insurance premium is only 12.5 per cent also has to be considered. ... & V. transaction, it was considered that a greater portion of customers would easily agree to renew their contracts. ... The precarious financial situation of the vendor cannot necessarily be considered as a negative indicator. ...

The debtor is considered to have disposed of the property for the principal amount of his indebtedness that is extinguished as a result of the creditor's acquisition or reacquisition of the property. ... Legislative history of section 80 The only provisions in section 80 that need to be considered for our present purposes are those found in subsections (1) and(4) of this section. ... It should not be overlooked that the deeming provision in subsection 80(4), that interest payable shall be considered as a principal amount, does not apply for the purposes of section 79 of the Act but applies only for the purposes of subsections 80(1) and 80(3) of the Act. ...

O'Hanley and the Imbrex controller reviewed the account of a supplier which yielded Packer a gross profit of 11 per cent which was considered low; Mr. ... The Supreme Court of New Zealand considered a case where a company deducted losses incurred by theft by a senior employee in computing its income: W.G. ... The amounts defalcated were considered by Packer to be a cost of goods. ...