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Parts of debt obligations (27) For greater certainty, (a) unless the context requires otherwise, an obligation issued by a debtor includes any part of a larger obligation that was issued by the debtor; (b) the principal amount of that part shall be considered to be the portion of the principal amount of that larger obligation that relates to that part; and (c) the amount for which that part was issued shall be considered to be the portion of the amount for which that larger obligation was issued that relates to that part. ... Matte’s argument that the “forgiven amount” of $245,812.39 has to be reduced to take into consideration the damages alleged in the counterclaim, counsel submits that the Settlement Agreement already considered such damages. ... Consequently, for a taxpayer who either becomes liable to repay money they borrowed or becomes liable to pay an amount (other than interest) as consideration for any property they acquired, the liability shall be considered to be an “obligation” for the purposes of applying the relevant provisions of the ITA. ...

Rémillard having told David Sutherland-Yoest what CWS considered to be its investments in Quebec [that is, about $200,000,000 in assets].... ... He considered that a substantial sum should be obtained from Carswell's as punitive damages ... In my opinion, the $12 million has to be considered to have been paid wholly for cancellation of the non‑competition agreements ...

Since the property is considered to be used in carrying on the business for twice as long in 2001 as it was in 2002, the full amount of $600 will be allowed for 2002 as the quantum of the payments to them correlates to the amount of time that the property was considered to be used to earn income in these years ... Since the house is to be considered to be used in the business for one-third of 2002, approximately one-third of this amount or $210 will be allowed for cleaning supplies for 2002.   ... We would also emphasize that although the reasonable expectation of profit is a factor to be considered at this stage, it is not the only factor, nor is it conclusive. ...

McAusland explained in his testimony, there had been very few hostile takeovers in France prior to Alcan’s bid and Pechiney was considered a “ fleuron ” or “ technological darling ” of France. ... Under this test, recurring expenses are considered to be current expenditures. ... [Emphasis added.] [179]    Prior to the enactment of that definition, income from property earned through a modicum of activity was considered by the case law to be income from an active business for the purpose of the small business deduction. ...

This clearly signalled a change in the factors to be considered in determining the amount to be added to a corporation’s capital dividend account upon the corporation receiving proceeds of a life insurance policy. ... Thus, the factors to be considered in applying the Reduction Provision after March 31, 1977 were more numerous than the factors to be considered in applying the Reduction Provision before April 1, 1977. [93]   In my view, the amendments made to the definitions of “capital dividend account” and “adjusted cost basis” in 1977 represented alterations in the law, rather than clarifications of the prior law. ... In a GAAR assessment the text is considered to see if it sheds light on what the provision was intended to do…. 109 ...

Implied repeal is sometimes considered a method of actual repeal rather than a rule of paramountcy. ... Paragraph 12(1)(x) was introduced to clarify the tax treatment of tenant inducements which in some cases the courts had considered to be tax-free ... Also, the phrase “may not reasonably consider” was considered in Canada Trustco v. ...

It seems likely then that a structure sensitive to the requirements of public shareholders, as well as to the Majority Shareholders, must have already been considered by the Appellants' advisers. [71]     Mr. ... Baxter testified that three different structures were considered as a means to purchase the ATCOR shares. ... The Queen, 2000 DTC 2428 at 2432 as a requirement for finding a series for tax purposes at common law, a requirement of a common subject matter or motivation emerges from all authorities considered. ...

Therefore, the application of the tie-breaker rules in paragraph 2 of Article IV of the Treaty will need to be considered and applied.   ... In that, he was not atypical of his contemporaries and the relevant factors must be considered in that context. ... Other aspects of the Gaudreau decision were considered by the Federal Court of Appeal and upheld at 2005 FCA 388 ...

The value of his pedigree plus the black gene would be considered worth pursuing as a young stallion ... I checked my figures with colleagues in the business of professional horse care, and these figures can be considered fair.   ... I checked my figures with colleagues in the business of professional horse-care and these figures can be considered fair ...

Asked if he considered the reserve calculations made by the Muscocho staff when the Mine closed in 1990, Mr. ... Lawrence only used "proven" so that what the Muscocho staff considered "possible" ore became "proven". ... Farquharson considered them to be two distinct categories. As far as Mr. ...