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Alternatively, the 2016 decisions considered whether AE was a placement agency pursuant to the provisions of the EIR and the CPPR. ... In 1392644 Ontario Inc. o/a Connor Homes v Minister of National Revenue, [7] Justice Mainville of the Federal Court of Appeal reviewed the cases in which the intentions of the parties were considered. ... As noted in Royal Winnipeg Ballet at para. 64, the relevant factors must be considered "in the light of" the parties' intent. ...

Next, the Court must determine whether each transaction in the series may reasonably be considered to have been undertaken primarily for a bona fide purpose. ... However, the entire series of transactions should be considered in order to determine whether the individual transactions within the series abuse one or more provisions of the Act. ... To the extent a shareholder receives an amount less than or equal to the PUC it will be considered a non-taxable return of capital. ...

The latter considered Ms. Garneau as his number two. At one time, Quincaillerie had a division that manufactured wooden stairs and various kinds of wood trim. ... This Court recently considered the tests stated by the Supreme Court in Sagaz in an employment insurance decsion. 6...   400.     ... Garneau considered the payer as “her” company. She held 25% of the voting shares. ...

Trudel‑Leblanc, the Federal Court of Appeal ruled that the Tax Court of Canada could not broaden the scope of an assessment to include transactions that the Minister had not considered in making the original assessment. ... In my view, the Minister could very well have considered the $70,000 as a benefit received from Pub in 1994, which Mr.  ... In fact, Article 3 of the separation agreement provided that that sale was not to be considered completed until Cyrano had officially fulfilled the conditions set out in the separation agreement. ...

I am of the view that, in such a situation, the invoice may be considered as a source of the GST registration number of the supplier and, depending on the circumstances, other information prescribed for the purposes of subsection 169(4) of the ETA, even though the invoice is not determinative of the time when the consideration becomes due or the GST is payable. ... They cannot succeed in that purpose unless they are considered to be mandatory requirements and strictly enforced. ... Although I have referred to the notes in the most recent edition of this book, in these Reasons I have quoted and otherwise considered the legislation as it read in 2006 and 2007. [35]   See the signature block in the email sent on August 24, 2007 by Mr. ...

Prothonotary Lafreniere in Apotex Inc v Wellcome Foundation Ltd, [2009] FCJ No 177, 343 FTR 41 wrote at paragraph 37: 37 Although the answers provided by GSK’s representative during examination for discovery are considered informal admissions, they can be qualified, enlarged upon, or even contradicted upon notice to the opposing party. ... Therefore, any comments made by the respondent at discoveries cannot be considered admissions. ... It would do no credit to our system of justice in Canada if the courts were restricted in their consideration of the merits of a case by an ill-considered admission that is inconsistent with another position that is being advanced, particularly where it is sought to withdraw such an admission at an early stage in the proceeding. ...

" The appellant submitted that his complaints about the conduct of CRA officials were considered by CHRC to have had merit and that this aspect of the matter is relevant to his case before the Tax Court. [5]      According to the Reply to the Notice of Appeal (Reply), the Minister issued assessments for the appellants 2000 and 2001 taxation years in which certain claimed business expenses were disallowed. ... This was never considered by the CRA. 18.        Ms. Kistner phoned the Appellant on January 15, 2004 stating that she would respond to the points raised in the document the Appellant presented at the last meeting and allow him an opportunity to respond. 19.        ... This was never considered by the CRA. 18.      Ms. Kistner phoned the Appellant on January 15, 2004 stating that she would respond to the points raised in the document the Appellant presented at the last meeting and allow him an opportunity to respond. 19.      ...

The first is to ensure that the Minister exercised his power appropriately. [38]     As found in Jencan, [1998] 1 F.C. 187, to which Malone J. referred in Quigley Electric, 2003 FCA 461, the decision resulting from the Minister's exercise of his discretionary power can only be amended if the Minister acted in bad faith, neglected to consider all the relevant circumstances, or considered an irrelevant factor. [1] If such a situation exists, the Court must decide whether the conclusion with which the Minister was "satisfied" still seems reasonable. [2] This is what the Federal Court of Appeal stated in Jencan: 31                 The decision of this Court in Tignish, supra, requires that the Tax Court undertake a two-stage inquiry when hearing an appeal from a determination by the Minister under subparagraph 3(2)(c)(ii). ... Wrights' Canadian Ropes Ltd., contends the respondent, unless the Minister has not had regard to all the circumstances of the employment (as required by subparagraph 3(2)(c)(ii) of the Act), has considered irrelevant factors, or has acted in contravention of some principle of law, the court may not interfere. ...

(a) to (i), the time and effort expended by the intermediary, the reliance of either or both the supplier and the recipient on the intermediary in the course of a supply of a financial service, the intention of the intermediary and, where applicable, the normal activities of an intermediary in a given industry, must be considered (including whether the intermediary is engaged in a financial services business). ...

They cannot succeed in that purpose unless they are considered to be mandatory requirements and strictly enforced. ...