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I find these documents to be very strong evidence that Gowlings considered itself to be counsel for Mr. ... Chaplin stated that she understood my concerns but that they were not something she considered at the time. [89] I do not believe her. [107]      All of the above suggests that the transaction was only recorded in 2007 because Mr. ...

Candace Keats, the CRA Appeals Officer who initially considered this matter, did not accept the expenditure as deductible because Mr. ... Therefore, I have not considered the cheque. [85]          See the untitled and undated two-page document submitted by counsel for the Crown to the Court on January 30, 2017. [86]          The price of the watch was $3,875 and the provincial sales tax was $310, resulting in a total expenditure of $4,185. [87]          The table of 2006 entertainment items is taken from Exhibit R-1, Tab 4, p. 15. [88]          See Exhibit R-1, Tab 4, p. 15. [89]          The table of 2006 marketing expenses is taken from Exhibit R-1, Tab 4, p. 16. [90]          Exhibit A-3, Tab 40, p. 4, item 19. [91]          Exhibit A-3, Tab 40, p. 4, item 23. [92]          Exhibit R-1, Tab 4, p. 16. [93]          The table of consulting fees is compiled from entries in the audit working papers; see Exhibit R-1, Tab 3, p. 13, and Tab 9, p. 30. [94]          Exhibit R-1, Tab 3, p. 14, and Tab 9, p. 31. ...

In any given case, the place where the tangible personal property is delivered or made available may be determined by reference to the place where the tangible personal property is considered to have been delivered under the law of the sale of goods applicable in that case. 9. ... Therefore, he considered that his dealership was already the owner of the RV when it was imported into Canada. [100]      I do not have any reason to doubt the testimonies of Mr.  ...

Water that is removed from the crude by the separators is treated to reduce residual oil content to below or at levels that are considered to be protective of the environment as prescribed by government regulation prior to being released to the sea. ... It was then shipped either directly to a purchasing refinery or to Whiffen Head for subsequent shipment to a refinery. [51]   In the circumstances, I have no difficulty concluding that the transporting/transmitting of the crude from the GBS to the shuttle tankers was sufficiently connected with the marketing of the crude to be considered an integral part of the production of the crude for the purposes of paragraph 1204(1)(b) of the ITR. ...

When I questioned him regarding possible errors in his analysis, he considered my questions and, if my analysis had merit, readily accepted that changes should be made. [9]   Mr. ... Yet he neither reported that revenue nor the purported losses on lines 162 and 135 of his returns nor completed a T2125 Statement of Business or Professional Activities. [95]   If I am wrong and the single pages that Paul Buday attached to the returns showing losses are sufficient for Paul Buday to be considered to have reported the business in his returns, then I find that he made omissions by claiming losses in a business that was clearly profitable. ...

He considered it to be a conclusion of law “that has no place among the Minister's assumed facts”. [25] I agree that legal statements or conclusions have no place in the recitation of the Minister's factual assumptions. ... Therefore, after having considered the evidence in respect of the Apple store policy, the purchasing patterns, the distinction between void and voidable contracts, and the doctrine of common law illegality, I am satisfied that Lohas could grant authority to the buyers allowing the agent to affect Lohas’ legal position. ...

The Queen, [1985] 2 C.T.C. 79, 85 D.T.C. 5310, the Federal Court of Appeal considered the issue of a taxpayer corporation engaged in the business of building logging roads and performing related site services under contract with owners of logging rights, and an investment tax credit claimed on equipment purchased for such use. ... Canada, [1990] 1 C.T.C. 134, 90 D.T.C. 6096, Martin J. of the Federal Court-Trial Division considered the matter in which the taxpayer acquired a diving support vessel and chartered it to Petro-Canada the same day for use in offshore exploration and drilling for petroleum. ...

It is generally considered that the cost amount of Canadian resource property which is distributed on the dissolution of a partnership is nil. ... From its point of view the contractual obligation was absolute, and the contractual obligation must be considered and the word “agreement” interpreted from its point of view. ...

There are a variety of manuals outlining how to manage ADHD children and medication is sometimes considered appropriate. ... C.A.), the Northwest Territories Court of Appeal considered the meaning of the word “certify” as it appeared in the Canada Evidence Act. ...

As set out above, that is not what Chief Justice Garon concluded. [163] In his dissent in CIBC (FCA), Justice Stratas stated that he was affirming “earlier decisions of the Tax Court of Canada and their supporting reasoning to the effect that reward points need not have a fixed dollar value in order to be considered a gift certificate”. [38] Justice Stratas referred to the specific paragraphs of Royal Bank in which Justice Hershfield interpreted the paragraph from Canasia quoted above. ... This may be the case, but it is not my role to fix problems with the Act. [243] If TD had been able to point me to any commonly understood meaning of “gift certificate” that would capture anything like an Aeroplan Mile, I could have considered its policy arguments through a purposive analysis of section 181.2. [244] A purposive analysis can either help the Court to choose between competing textual interpretations or reveal unexpected textual ambiguity. ...