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The Appellant argues that my earlier finding that the right of exclusivity was simply a bargaining tool and was not to be considered a supply of anything (property or services) by Costco to Amex is unaltered. ... But, there were many other factors considered by Amex in agreeing to charge only Z. ... Why could it not be thrown into the factors considered in Y? The Respondent has not proven on balance any allocation of Y to any elements of the deal ...

., [22] Justice Mogan considered the question of an inside director versus an outside director where there was a sole director who relied on her husband to be responsible for corporate management. ... R., [23] I considered Justice Mogan’s views on this matter and came to the same conclusion there as I have in the case the bar: 11     By definition then an insider is a person involved in the business. ... He considered the appeal of directors who were facing liability for the corporation not having remitted taxes under the Income Tax Act. ...

Poulin stated that he had run the business as best he could given the knowledge he had, which he himself considered inadequate. ... However, an analysis of what he considered to be different, if not contradictory, versions, does not support such a conclusion. ...   [63]          What the auditor considered to be contradictory versions is rather a demonstration of the ambiguity of the situation and the obvious candour of Mr.  ...

The 22 hours claimed for consultation and revision of prior reports and to prepare the court report were not challenged by the appellants and are considered reasonable. ... Brodeur's hourly rate was not challenged and is considered reasonable. ... In support of this claim, the respondent cited the following cases on experts who did not testify, but whose costs were considered recoverable: Buddy L. ...

There was evidence submitted that if the course didn't qualify for a business expense, then it should be considered as an employment expense. ...   [28]     It does not seem to me that the personal reasons for acquiring the products can simply be ignored or considered insignificant. ...   [39]     However, as noted above, it seems to me that a portion of the travel costs could be considered to be for the purpose of earning income. ...

  [35]          The witness was asked if he had considered whether the Appellant may have been carrying on business in Canada in the taxation years in question. ... He suggests that the facts of the present case are different from the facts considered by Mr.  ...   [48]          The facts of this case are very different from those considered in the Thomson case, in which Mr.  ...

No. 56 (T.C.C.) at para. 95. [39]          The question of whether, and in what circumstances, a person’s undertaking of an activity for which the person receives funding from a government body constitutes the making of a supply to that body for consideration was considered by the Federal Court of Appeal in Des Chênes (Commission scolaire) v. ... Bell J. considered each grant agreement to determine whether under its terms the amount of the grant was “payable” by the Province. ... But when the leasing transactions are considered independently, London Life is supplying the leasehold improvements to the landlords for the consideration of the leasehold improvement allowances. ...

She was considered an employee (under a contract of employment) because Énergie Cardio made all the source deductions for taxes, Québec Pension Plan contributions, and Employment Insurance (EI) premiums. ... Rhéaume says that she was paid as an independent contractor but considered herself an employee ... Faucher considered this approach appropriate. As far as the second class was concerned, Ms.  ...

He considered himself to be self-employed; in addition to his contract with Mr.  ... Levert and the other two truck drivers that they entered into an agreement under which they were considered to be self-employed workers. ... In my opinion, however, this factor alone does not affect the agreement between the parties, under which both parties considered the drivers to be self-employed workers ...

  [16]    He considered the trainer to be a competitor but a blacksmith was not a competitor. ... That Technical Note indicates that the awarding of the prize is not considered to be a supply, nor is the prize itself considered to be consideration for any supply ... Counsel referred to the Rulings letters dating back to 1992 in support of the argument that the Minister even considered these amounts not to be taxable but then changed his mind ...