Search - considered

  [6]      In order to resolve the issue before the Court, the total relationship of the parties and the combined force of the whole scheme of operations must be considered. [1] To this end, the evidence in this matter must be subjected to the four‑in‑one test laid down as points of reference [2] by Lord Wright in Montreal City and adopted by MacGuigan J.A. in Wiebe Door. ...

As the parties considered that they were engaged in an independent contractor relationship and as they acted in a manner that was consistent with this relationship, I do not believe that it was open to the Tax Court Judge to disregard their understanding (compare Montreal v. ...

In other words, the acquisition of the hotel and the lands adjacent thereto was to be considered as a whole, that is to say, as an adventure in the nature of a trade, not an investment project generating an enduring income benefit ...

The appellant explained that the payment of these taxes was considered rent Messrs. ...

We cannot know if the result would have been different if this subsection had been considered by the Court ...

Minister of National Revenue [1986] 1 C.T.C. 2288, 86 DTC 1235, Justice Sarchuk made the following comments:   11     The Johnston case (supra), was considered in Hillsdale Shopping Centre Limited v. ...

      [10]          Even if the Worker had satisfied me that he truly did 200 hours of work, those hours would not have been considered insurable, because they would not have been under a contract of service, since, in my opinion, that contract was entered into on or after June 15, 2007, not in or before March 2007. ...

The testimony of Bianca Dubois   [7]               The testimony of Bianca Dubois, which, in my opinion, must be considered with a great deal of caution since she is currently the worker's common-law spouse, would yield fairly little information in any event, other than that she witnessed the signing of the document constituting Exhibit A‑5 by Mr.  ...

  [23]          Even if it was considered that the amounts transferred were not received by the appellant pursuant to subsection 146.3(5) of the Act, the amounts would nevertheless have to be included in the income of the appellant pursuant to subsection 56(2) of the Act ...

The relevant facts were considered, and the conclusion was reasonable. ...