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In my view, this tax advantage should not be considered in determining whether Dr. ... There is just one interconnected arrangement here, and no part of it can be considered a gift that the appellant gave in expectation of no return. ... ”   [43]         This Court subsequently considered the implications of McNamee in the recent case of Kossow v. ...

Reeder, 75 DTC 5160 (F.C.T.D.), referred to by the appellant, the court listed some factors considered to be material in determining the question of fiscal residence, at page 5163:... ... Judge Mogan considered the decision by Judge Sarchuk of this Court in Ferguson v. ... In that, he was not atypical of his contemporaries and the relevant factors must be considered in that context. ...

The letter confirmed that C.C.R.A. considered financial assistance and scholarship awards such as that granted to the Appellant to be taxable benefits. ... Again, the letter reminded the parents that C.C.R.A. considered financial assistance to be a taxable benefit with only the first $3,000 of such assistance received on a tax-free basis. ... That is the right that is being considered under section 248 of the Act in using the term "amount". ...

Counsel for the respondent reviewed the transcript citing examples of what she considered the deponent's unreliability. ...   [32]          During the course of the audit, counsel informs me, the Minister considered but decided against reassessing pursuant to paragraphs 247(2)(b) and (d). ...   [34]          The Crown also alleged in its reply that subsection 56(2) of the Act and the doctrine of sham may apply, allegations that were not considered during the assessing process. ...

The Queen, Justice Beaubier also considered the issue of whether or not certain workers were full-time employees. ... That limited level of activity was considered by Parliament to be too low to warrant be considered "active business" and gaining the tax benefits that go with that label. ... What was considered to be the normal or standard amount of time for janitors to work during the years in question? ...

He considered this to be something special. He would not have put this labour into the project if he had thought that they were going to move. ... They must have considered that they would have children if they were going to stay there for the rest of their lives. ... R., 2000 DTC 2086, where this Court also considered Happy Valley Farms Ltd., supra, and other cases on the issue. ...

(r)                   as a consequence of the aforementioned series of transactions a tax benefit was conferred on the appellant and the Minister considered that the increase in the paid-up capital of the class C shares from $1.00 to $76.40 a share was an abuse;... ... The fact that her son was at the centre of the eventual purchase undoubtedly tended to make her more flexible: in other words, the appellant was undoubtedly more co-operative and conciliatory as she had a clear and natural interest in having the business remain in the family. [59] That being so, the experts she hired studied and analysed all the information and considered the special concerns of the appellant and her son; they suggested various scenarios, describing the tax consequences of each. ... I had considered recalling counsel to argue the effect of the case but since it confirmed the conclusion which I had reached in any event I did not consider that I was justified in doing so. ...

This caused the Appellant to be more conservative in its activities in the 1980s, which it considered prudent business sense. ... The Appellant would obtain the benefit it considered would flow from the application of the provisions of the Acct. 3. ... Rawson relied on Frank Sabo for these values and considered his values to be reliable. ...

The respondent argued that from 1969 to 1977 the appellant has always considered the apartment buildings it owned as inventory. ... In general, property which is retained in inventory is considered to have been acquired for resale. ... Certain elements may be considered which confirm or negate the contractor's assertion as to its original intention. ...

No plans to do so were being considered. Ski Facilities: Prior to Mr. ... It is generally a flat, sandy area and Kokanee Springs initially considered it to be prime property for recreational development. ... No further development was being considered in this area. In 1972 a provincial election took place and a new government resulted. ...