Search - considered

As noted in Royal Winnipeg Ballet at para. 64, the relevant factors must be considered "in the light of" the parties' intent. ... Judicial silence is no longer considered to guarantee impartiality and neutrality in the decision-making process. ... [Emphasis added.] [35]   For an example of a part-time worker who was considered an employee by the Federal Court of Canada, see Rosen v. ...

Thirdly, it includes items that might be considered unusual for people seeking to limit grocery food purchases to fill-in items and perishables. ... This leads me to conclude that the only explanation is unreported business income. [233]   Liability for penalties must be considered separately for each of the Appellants. ... The house was considered an asset at the end of 2007, the base year for the net worth assessment. ...

Sood Counsel for the Respondent: Pascal Tétrault Benjamin Grant Veronica Pinero   JUDGMENT Having considered the evidence and the submissions presented by the parties, and in accordance with the attached Reasons for Judgment (the “Reasons”), IT IS ADJUDGED THAT: The Appeals are allowed and the reassessments that are the subject of the Appeals are referred back to the Minister of National Revenue for reconsideration and reassessment, on the basis that, for the reporting periods that are the subject of the Appeals, the Appellant is entitled to additional input tax credits in the amount of $97,125.55, subject to paragraph 229 of the Reasons. ... The above submissions will be considered below. First, however, it would be helpful to consider more closely the relationship between the REIT and the LP, and the nature of the Services, in order to ascertain which, if any, of the Services were suitable for acquisition by the REIT, in its capacity (if any) as the agent of the LP. ... This can be expected to require more [than] the Respondent’s suspicions. [153] [189] Having considered the evidence, I am satisfied that the REIT and the LP presented the Agency Agreements as creating an agency relationship between them, which is the relationship that the REIT and the LP intended to create. ...

Sinnott considered the fact that legitimate businesses do not use cash houses to cash their cheques but instead will deposit their cheques into regular business bank accounts. [124] Further, Ms. ... Only in exceptional circumstances would a Court find that the traveling from home to one’s place of business (or employment) would not be considered a personal expense (Campbell v. ... Sahi should have known that the Subcontractors were not capable of supplying any labour services. [368] Furthermore, I considered the following factors for concluding that Mr. ...

Bellfield can be considered a pioneer. [10]   According to the testimony of certain individuals, some believed that Mr. ... Canada, [24] the Federal Court of Appeal considered the deductibility of expenses that the taxpayer paid to an agent in efforts to sell certain precious gems. ... Canada, [60] the Supreme Court of Canada considered the proper inquiry for the income-earning purpose test under subparagraph 20(1)(c)(i). ...

That paragraph reads as follows:   [85]      It may be useful at this stage to summarize the principles of corporate and taxation law considered in this appeal, in light of their importance.  ...   (4)        Documents other than the share register, the constating documents, and any unanimous shareholder agreement are not generally to be considered for this purpose ... A corporation the voting shares of which are distributed among a large number of persons is usually not considered to be controlled by any group of its shareholders, provided the shareholders do not act together to exercise control. ...

A I considered it, but in short of having something to support it, what was I going to do? ... Taken at its most anodyne, this description of his activities could reasonably be considered part of the corporate management services Longview was able to provide. [154]    Mr. ... In your opinion, what are the appropriate data and economic factors to be considered when determining what an arm's length person, standing in the shoes of [the Appellant], would have agreed to pay for the services described below [in the Factual Assumptions provided to Mr. ...

I agree that, in deciding whether or not any activity may be classed as a business under the provisions of s. 7(1)(b) of The Assessment Act, all relevant factors regarding an operation must be considered and weighed. However, they must be considered and weighed in order to determine not whether in some general sense the operation is of a commercial nature or has certain commercial attributes, but whether it has as its preponderant purpose the making of a profit. ...

Her finding was confirmed by the advance rulings directorate after it considered the parties’ representations.   ... Analysis   [23]          Subsection 256(2.1) of the ITA provides as follows:   (2.1) Anti-avoidance ― For the purposes of this Act, where, in the case of two or more corporations, it may reasonably be considered that one of the main reasons for the separate existence of those corporations in a taxation year is to reduce the amount of taxes that would otherwise be payable under this Act or to increase the amount of refundable investment tax credit under section 127.1, the two or more corporations shall be deemed to be associated with each other in the year ...

Glegg indicated he considered himself and his holding company to be one and the same. ... Barrett’s evidence, that the Tax Court’s decision in Fortino was not considered, and Mr. ...