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ANALYSIS (a) Morrison and Eisbrenner [17] In Morrison, the Tax Court of Canada considered the denial of charitable donation tax credits claimed by Mr. ... Morrison’s appeal with respect to the charitable donation tax credit for participation in the CGI Program. [20] In Eisbrenner, the Federal Court of Appeal considered the appeals by Mr. ... The Tax Court considered whether the “inflated tax receipt” for the CHT in-kind donation vitiated Mr. ...

If after that process it is found that there is ambiguity about what was intended, parol evidence may be considered. ... Can the payment reasonably be considered to have been received as assistance in respect of an outlay or expense? ... The question of determining fair market value where only one side presents an expert was considered by Bowman, A.C.J.T.C. in Klotz v. ...

The documents explaining the different planning options considered, including three (3) alternative reorganization projects, were entered into evidence. ... As a result, no premium can be considered to have been paid at the time of the acquisition of control of 3295 in 1996 that would not have been reflected in the ACB for Holdings shares. ... Essentially, all the money considered received in 2002 during the sale of 3295’s assets was redistributed to Micsau in the form of dividends between 2002 and 2004. 125. ...

Duhamel’s testimony, when considered with common sense, are entirely plausible. [64] First, Mr. ... This objective factor of commerciality must be considered in similar situations. ... Duhamel did not obtain this 37% return on investment when all the results of his gambling activities are considered. ...

This will be evident once the function that each of the definitions plays in the scheme of the Act is considered. [72] Numerous provisions of the Act distinguish between a public corporation, a CCPC and a private corporation. ... Such corporations will then not be considered resident in Canada unless their central management and control are located in Canada. ... For example, the Appellant was no longer deemed to be resident in Canada, no longer considered to be a Canadian corporation and no longer considered to be a CCPC. [231] The fact that it remained a resident in Canada did not frustrate the object, spirit and purpose of subsection 250(5.1). ...

He considered the unpresented cheques to be a liability to Canfor for accounting purposes and they are shown as such in the financial statements. ... It is at this time that the bank has made available to the borrower the use of the funds. [9] [54]     The Courts have considered the application of the Part I.3 tax in a number of cases albeit none directly on point with the issue here today. ... In common law jurisdictions delivery of a cheque constitutes payment at that time. [90]     The writing of a cheque on a bank account is considered to constitute a draw upon that account where that cheque represents payment. ...

Poulton considered him to be the "whole company" in all the decisions with respect to Oakamp Developments. ... That is when it was considered that the loan was forgiven. At that point in time there was no more loss available to be reduced. ... If he was told that it need not be reported then he may have avoided being considered to be negligent or careless. ...

Each supply must be considered as an independent supply for tax purposes, the single consideration being apportioned among the separate supplies as appropriate.   ... One factor to be considered is whether or not the alleged separate supply can be realistically omitted from the overall supply. ... These services in themselves are not otherwise considered to be financial services under paragraphs (a) to (m) of the definition in subsection 123(1) of the ETA. ...

A limit on the amount paid in respect of a particular claim to what is considered “reasonable and customary”. ... However, the maintenance of DIN price and formulary files and DUR files for use in the adjudication process cannot be considered to define the essential character of the supply provided by Emergis to Great-West. ... It is worth noting that this regulation will affect only services that would otherwise be considered to be financial services under paragraphs (a) to (m) of the definition under subsection 123(1). ...

In the alternative, if he were to be considered a de facto director of 9056, Mr.  ... Under these circumstances, this should not be considered an example of an action taken by a director. ... If the ARQ made such an assessment in respect of Mehmet Koskocan, it was because it considered him a de facto director. ...