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The Deal Fee was “paid” by Taylor having the $3,774,241 discussed previously in its bank account at the time that Meston purchased its shares from PIRG for $2,944,616 ($3,774,241 − $2,944616 = $829,625). [44] The parties state at paragraph 96 of the PASF that “the principal reason for the [Share Purchase Agreement] and Meston inheriting Taylor’s 95% allocation of Partnership income may reasonably be considered to be the reduction of the tax that might otherwise have been payable under the Income Tax Act (Canada)”. [45] Mr. ... The use of the word “raisonnables” in the French version of the provision supports this interpretation. [38] The use of a reasonableness requirement in tax legislation has been considered in other contexts. ... Subsection 103(1) concerns only the reasonable allocation between the Appellant and Meston. [67] However, even if Taylor is considered, the Minister’s allocation is still correct. ...

Some were considered as full-time workers and were paid an hourly wage. ... Some varieties – such as Blue Crop – are considered to be high-yielding plants. ... Turgeon’s notes indicate she considered Rajinder had done most of the talking. ...

Stephens feared legal action was being considered, so he tried to contact Mr. ... She never received any payment from the investments that she considered hers. ... This may not be considered by Mr. Rezek, in hindsight, as money well spent. ...

Certainty of intention is a question of construction; the intention is inferred from the nature and manner of the disposition considered as a whole. ... These sales were researched but not included in the preceding sales chart as they are not considered as comparable to subject property. ... No one was able to tell me why it was not used as a comparable or why it was not the best indicator of value of all of the properties considered. [55] Were it not for the Lagace/Cormier sale, I would probably have considered Mr. ...

Gagnon added, however, that he considered that debt in the percentage of debts owed to the Bermex group. [24]     Also on cross-examination, Mr. ... Normand considered four criteria in order to determine whether they were operating or capital expenses. ... As a rule, it is of little importance if a few boards on a balcony and a few lengths of pipe are replaced each year-the expenses incurred would unquestionably be considered current maintenance expenses-or that having neglected to maintain the property, major and lasting repairs have to be done. ...

In addition to the general factors described above, the composition of the board of directors and the control of day-to-day management and operation of the business would be considered. ... It is merely a limited personal right to be considered as a potential beneficiary that can be exercised only against the trustee. ...   [49]         Once it has been determined that each beneficiary of FFL’s capital was "beneficially interested" within the meaning of subsection 248(25), it should be considered whether they were also "beneficially interested" for the purposes of subparagraph 251(5)(b)(i) ...

In the first agreement, different rates were applied depending on whether the licensed products were considered “established technology” (5%) or “new technology products” (7.5%). ... Here the focus is on the attributes of ownership of the payment/item to be considered. ...   [28]     In the scenario such as the one before the Court, where it must be considered whether the recipient can be considered a conduit, one must take a close look at where the right to use and the enjoyment and assumption of risk and control of the payments lie. ...

Although the tie-breaker provisions in the Canada-Korean Tax Convention were considered, this part of his analysis is obiter. ... In this case also all stays made in a State must be considered without it being necessary to ascertain the reasons for them.   19.       ... Paragraphs 9 and 10 of the Commentary to Article IV(2) illustrate the context in which the tie-breaker rules are to be considered:   9. ...

Analysis The issue of whether a particular expenditure is an income expense or a capital outlay has been considered on numerous occasions by the courts. ... He also went on and said the agreed method of payment provided an indicator, or at least an inference that the purchased customer lists were considered in the nature of a profit yielding asset capable of projected earning capacity. ... In short, we think that he carefully considered the nature and substance of the transaction which the applicable jurisprudence requires him to do. ...

The goods are considered seller’s property up to the moment they are fully paid for by buyer. ... In Bendahmane, supra, the Court considered, inter alia, the Refugee Claims Backlog Regulations (SOR/86-701). In Granger, supra, the Court of Appeal considered the Labour Adjustment Benefits Act, S.C. 1980-81-82-83, c. 89. ...