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She considered her sales targets, which were set by the company each March, to be high and noted that as she met them, her targets for the following year increased. ... For example, in Templeton v R [1998] 3 CTC 207, the Federal Court considered a scenario where the taxpayer was employed as a broadcaster‑commentator for a radio station. ... In this case, the Federal Court suggested that the four elements laid out in Bracken need not necessarily be considered as four separate elements. ...

Khunkhun to summarize the factors to be considered by the Court in exercising its discretion to allow an individual to represent a corporate appellant in the General Procedure, he was unable to do so. ... No Financial Impediment to Retaining Counsel [17] One of the factors to be considered is whether the corporate appellant is able to afford legal services. ... Khunkhun Would be Unable to Represent the Appellant at Tria l [20] As Justice Jorré noted in WJZ Enterprises v The Queen, one of the factors to be considered is: 6. ...

Legal framework [7] Subsection 147(3) of the Tax Court of Canada Rules (General Procedure) sets out the factors which may be considered by this Court in determining costs. ... The significance of the amounts in issue must be considered contextually and in relative terms. [14] From this perspective, the amounts are not significant. ... (d) Any offer of settlement in writing [12] No written settlement offers were made so substantial indemnity costs cannot be considered. [15] Therefore this factor is neutral. ...

This investment is considered an investment in a long-term receivable (i.e. ... The Lease Contracts and Lease Receivables are not considered tangible non-financial or capital assets and cannot be considered tangible property. ... "Land, buildings and equipment" are considered "tangible property" under GAAP. ...

However, the expert for the respondent considered this height at times as an indication of obsolescence (although no related adjustments were made) and at times as an advantage, as will be seen. ... He considered this valuation to be the most representative because he identified 11 different transactions involving industrial warehouse-type buildings in the greater Québec area between October 1995 and January 1999. ... As well, in his testimony the expert for the respondent admitted that the price of lots in Vanier was $20 or more per square metre, not less than six times as much. [52]     In comparing the advantages and disadvantages of one building with those of another building that both experts considered comparable in a number of respects, the experts each found points they considered important in supporting their respective hypotheses. ...

Andrews reviewed and considered relevant for establishing her assessing position. ... If the GAAR Committee had considered the Appellant’s case, there is no doubt that the Appellant would be entitled to discovery of all non‑privileged documents considered by the GAAR Committee in deciding to assess the Appellant under the GAAR. [86] In my view, the Appellant is equally entitled to all non-privileged documents considered by the GAAR Committee in deciding to assess under the GAAR the unrelated taxpayer described in the Similar Case Excerpt because that decision directly resulted in the subsequent decision to assess the Appellant under the GAAR. Consequently, the documents considered by the GAAR Committee in making the first decision are in effect the basis for the CRA’s subsequent decision to assess the Appellant under the GAAR even though those documents do not address the Appellant’s transactions. [87] I therefore find that the documents requested by the Appellant in item 8 of the Schedule that were considered in the meeting or meetings of the GAAR Committee described in the Similar Case Excerpt (the “GAAR Committee Documents”) are relevant for the purposes of discovery. ...

He considered Nigeria as his place of permanent residence. He did not consider Canada as his place of permanent residence or as one of them. ... He also received advice from the IRS in the U.S. through the hot-line, which is another factor to be considered. ... In any event, he filed objections and that is why the case is before the Court. [86]          Therefore, even though filing tax returns is clearly a factor to be considered, and clearly a tie to be considered, those tax returns that were filed in 1999 in Canada, based on Canadian residency, were filed after the period in question and there was a clear explanation for that, which does not support the finding that he considered himself to be a factual resident of Canada during the years in question. ...

There was also evidence to suggest that taxation was not considered in the formulation of the business plan. ... The Court considered whether two groups of lumber companies which were owned by three brothers were associated. ... The Court considered an operating corporation, Bryan's Fashions, which was owned by two corporations. ...

Although she seems to have considered following Mr. Gagné to Québec, Ms. ... At page 51, the Court added the following:                         Certainly an opposite-sex couple may, after many years together, be considered to be in a conjugal relationship although they have neither children nor sexual relations. ... Therefore, they must be considered as spouses during the 1996, 1997 and 1998 taxation years and base taxation years. [36]          The appeals are accordingly dismissed. ...

The point to be taken from these decisions is that the amounts paid by a trustee to an employee as vacation pay cannot be considered to be earnings at the time they are paid. ... Paragraph 10.2(a) states that an hour of work performed in insurable employment is considered to be a single hour of insurable employment, even if the hour is remunerated at an overtime rate of pay. [37]          In conclusion, since the vacation pay amount is considered as remuneration earned during the weeks of employment, no additional insurable hours may be credited under section 9.1 of the Employment Insurance Regulations for the 11 percent vacation pay amount. [38]          The appellant is deemed to hold insurable employment solely for the hours he actually worked. ... Paragraph 10.2(a), as my colleague emphasized, states: (a) an hour of work performed in insurable employment is considered to be a single hour of insurable employment, even if the hour is remunerated at an overtime rate of pay. ...