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She would then claim an input tax credit so that the amount of GST that was actually remitted to Revenue Canada was equal to seven per cent of the actual profit on a net-fare transaction, which she considered to be the real commission or consideration received by the appellant on such a transaction. ... The direct car sales allowances were therefore considered not to be discounts as they did not result in a lesser price to the consumer at the retail level. ...

He considered various ways that this could be done. As residential real estate was the business that he knew, and as it was generally considered to be a sound investment, he decided to invest in income-producing real estate. ...

At the time, she considered that to be a fair wage and she and the children lived in the upstairs portion of the farm house owned by Almey. ... It is obvious the Minister considered the long-standing living arrangement of the parties and concluded their relationship was more than employer-employee. ...

He did not consider all of the factors he should have considered, nor did he assess the context fully. ... The following criteria should be considered: the profit and loss experience in past years, the taxpayer's training, the taxpayer's intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...

It stated that if a profit had been obtained that it would be taxable and that, accordingly, the sums advanced were considered as outlays for gaining income from an adventure in the nature of trade. [45] Appellant's counsel then referred to Kleinfelder v. ... The following criteria should be considered: the profit and loss experience in past years, the taxpayer's training, the taxpayer's intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...

The Income Tax Act does not prescribe factors to be considered in assessing the collectibility of a debt. ... If there is some evidence of an event that will probably occur in the future that would suggest that the debt is collectible on the happening of the event, the future event should be considered. ...

This Court considered this issue in Lavoie v. The Queen, 2009 TCC 293. ... Further, even if his testimony is true and complete, it cannot be considered reasonably sufficient in any event. [21]         My credibility concerns with Mr.  ...

They are not assumptions under paragraph 14 like the provisions considered by Chief Justice Rip, the onus of which falls on the Appellant to demolish, so I am not convinced there is any prejudice to the Appellant in this regards. ... I’d ask you to identify each instance where the actual legal relationships between [Cameco] and [CEL] in respect of any contract or transaction which it considered relevant, differs from the legal relationships reflected in agreements between [Cameco] and [CEL]. … 1120                Q.        ...

In my view, it is only when property is supplied pursuant to an agreement that is referred to as a lease, but which requires the recipient, at the time the supply is made, to purchase the property, that the so-called lease may be considered a sale for the purposes of the GST Act. [70]         Counsel for the Appellant also argued that it is not in every situation that an option results in a sale. ... Bird, page 197. [16]          The amount assessed was equal to the GST payable on the fair market value of the 44 Terravita Condo Units minus the amount the Appellant self-assessed in respect of the Monthly Lease Payments; Transcript, page 230. [17]          Section 165. [18]          See Sections 2, 3 and 4 of Part I of Schedule V to the GST Act. [19]          Section 6 of Part I of Schedule V to the GST Act. [20]          Section 225. [21]          This is a result of the operation of subsection 221(1). [22]          Subsection 152(2), assuming that the residential condominium unit is supplied under an agreement in writing. [23]          Subparagraph 191(1)(b)(i). [24]          Generally speaking, the supply would not constitute an exempt supply since the supply was made by the Appellant, who is considered the builder of the condominium units for the purposes of the GST Act. [25]          Section 133. [26]          Subsections 165(1) and 221(1). [27]          Subject to the rules in subsection 168(6) for non-ascertained consideration and assuming that possession of the unit is not given to the recipient prior to the closing date. [28]          See section 191. [29]          Subsection 136(2) allows for the splitting of a single supply of real property comprising both a residential complex and real property that is not a residential complex. ...

Cimbert considered herself a worker when she was hired by the appellant.    ... However, the Court of Québec and the Court of Appeal of Québec have both considered, among other things, the elements of legal subordination to arrive at their decisions.    ...