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The reimbursement of these expenses cannot be considered as conferring a benefit within the terms of the Act. ... While reimbursement by an employer for an actual loss suffered by an employee or for an additional expense incurred as a result of a transfer has not been considered to be a benefit within the meaning of paragraph 6(1)(a) (see Ransom, supra, Splane, supra and Hoefele et al., supra), the payment of a lump sum or other sum not of this directly compensatory nature, including a payment to reflect a higher cost of living, has been considered to be an improvement in the taxpayer’s economic situation or an enrichment, and thus, to be a taxable benefit (see Phillips, supra). ... The more acute problems of persons living in northern or intermediate areas have also been considered on more than one occasion and were made the subject of the special provisions of section 110.7 with a view to providing an adequate and fair solution to those problems. ...

I would have found on a factual basis that it could not be so considered. ... He then said there were some issues in Scandinavia and said that Canada was considered, the U.S. was considered, and Barbados was considered.  ... He said that the Tax Department was considered an integral part of the Finance Department. ...

Integration is not part of the four‑in‑one test and it is considered rather difficult to apply. ... It has not been considered by the Supreme Court of Canada. If it is considered by the Supreme Court of Canada the dissenting judgment of Evans J.A. in Royal Winnipeg Ballet will have to be taken into account.   ...   [36]      I have considered this case on the basis of four alternative hypotheses. ...

Firstly, the issue was directly considered by the Federal Court of Appeal in National Capital Outaouais Ski Team v. ... The Wiebe Door factors must also be considered to determine whether the contractual intention suggested by the intention clauses is consistent with the remaining contractual terms and the manner in which the contractual relationship operated in fact. [22]          In City Water, supra, the Federal Court of Appeal considered the four-in-one test factors and only when they did not yield an obvious result, considered the weight to be given to the mutual intention of the parties. ... The Worker testified she considered her remuneration competitive as well. ...

The delictual act cannot in that case be considered as being necessary for carrying on the trade or profession. ... , [17] Lamarre Proulx T.C.C.J. considered the question of whether the packaging of animal food was a processing activity. Her Honour states at page 1545: Packaging is considered as the final phase of manufacturing activities. ...

The significance of intention as one of the factors to be considered was emphasized by the Supreme Court of Canada in Friesen v. ... In that case Major J. summarized certain important factors to be considered in determining whether a transaction in real estate is an adventure in the nature of trade. ... Thus, where the nature of a taxpayer's venture contains elements which suggest that it could be considered a hobby or other personal pursuit, but the venture is undertaken in a sufficiently commercial manner, the venture will be considered a source of income for the purposes of the Act.... 62             In this case, the appellant was engaged in property rental activities. ...

Miller during her lifetime with power to the executors and trustees to pay or use for her benefit, such part of the capital as they, in their absolute discretion, considered advisable. d)             Upon the death of Mrs. ... 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 ...

He submitted, however, that it is to be considered "an active business asset" for two reasons: Mr: Crossingham: First of all, the company clearly filed in that fashion and the Department has not objected. ... The only other asset considered was the short term deposit of $171,000 shown in Palmela’s financial statements. ... There is no reason why any income earned by it should not be considered as prima facie income from a business so long as it is recognized that the presumption is a rebuttable one. ...

He considered the offer to be fair to both sides. He was aware of Alias, its expertise and reputation. ... McClintock said financial statements were considered. He also suggested that a valuation had been prepared. ... For a valuator's opinion on whether a subsequent sale may be considered, see Ian R. ...

The Income Tax Act does not prescribe factors to be considered in assessing the collectibility of a debt. ... The case law is clear that under paragraph 50(1)(a), either all or a portion of the debt may be considered bad ... " [23]   [31]     Considered in light of the principles in Rich as discussed above, the evidence satisfies me that Mr. ...