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To that end, Zaeri and other members of the business group considered Eleniak's sole responsibility to be a marketer of their products and service in an effort to increase sales. ... The most that can be said is that control will no doubt always have to be considered, although it can no longer be regarded as the sole determining factor; and that factors, which may be of importance, are such matters as whether the man performing the services provides his own equipment, whether he hires his own helpers, what degree of financial risk be taken, what degree of responsibility for investment and management he has, and whether and how far he has an opportunity of profiting from sound management in the performance of his task. ...

Grice stated he considered his tools to be composed of his special skills, extensive organ library, metronome, computer and software for cataloguing music, office supplies and special shoes- with very thin soles- for playing the organ. ... Grice stated that he was considered- by virtue of paragraph 6 of the contract- to be an ex officio member of the Worship and Music Committee but he was not a member of the congregation at Young. ...

Canonne stated that honesty was a cultural matter, and that in that culture documents were superfluous. [18]          He even claimed that to require documents could be considered as an insult and as casting doubt on one's honesty. ... Rompré said to me one day, I don't know if I telephoned him in Montreal or from the Bahamas, I don't remember, but he told me that the money market was finished, that the good times were over for the money market and that some other kind of investment would have to be considered.                 ...

The Queen, 96 DTC 1520. [56]          In that case, the Honourable Judge Hamlyn found that investment income was taxable personal property after considering the various connecting factors for determining the situs of that income. [57]          He thus considered the following aspects: the residence of the appellants; the origin or location of the capital used to buy the securities; the location of the bank branch where the securities were bought; the location where the investment income was used; the location of the investment instruments; the location where the investment income payment was made; and the nature of the securities, and in particular the residence of the issuer, the location of the issuer's income generating activity from which the investment was made and the location of the issuer's property in the event of a default that could be subject to potential seizure. [58]          In keeping with the case law, Judge Hamlyn did not attach the same importance to each of these factors; however, he accepted and recognized that the Indian's place of residence was crucial. ... He stated the following:                ... where investment income is at issue, it must be viewed in relation to its connection to the Reserve, its benefit to the traditional Native way of life, the potential danger to the erosion of Native property and the extent to which it may be considered as being derived from economic mainstream activity. ...

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. ...

He also argued that even if the Court was not bound by the relevant Information Circular, his course of conduct and his spirit of cooperation should be considered as factors bearing on the issue of penalty. [41] The Appellant maintained in his summation the proposition that the only amount he received from Mr. ... It is clear that this payment could not be considered as a gift. The Appellant recognized that when he was first retained by Mr. ...

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. ...