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He asked officials at Revenue Québec if he could obtain guidelines or criteria regarding member participation so that they would not be considered specified members, i.e., what a member must do to not be a specified member. ... In this respect, equity legislation that permits interest to be cancelled or waived in certain situations will be fully considered. ...

These circumstances must be taken into account, but must be considered against an objective “reasonably prudent person” standard. ... Although no investor was ultimately found, the Court considered that it was reasonable of the directors to believe that, had an investor been found, the failures to remit might have been prevented. ...

For tax purposes, damages or compensation received, either pursuant to a court judgment or an out-of-court settlement, may be considered as on account of income, capital, or windfall to the recipient. ... Applicable law [160]    Section 16.1 of the Tax Court of Canada Act provides that the Court may, on application, hold a hearing in camera if the circumstances justify it: 16.1  A hearing before the Court may, on the application of any party to a proceeding, other than Her Majesty in right of Canada or a Minister of the Crown, be held in camera if it is established to the satisfaction of the Court that the circumstances of the case justify in camera proceedings. [161]    In Union Carbide, the Supreme Court of Canada noted that a party that wants to keep confidential, or sensitive, evidence from the public may apply to have it considered in camera. ...

Knowing that the meeting of February 23, 2009, lasted only about 45 minutes, and considering the size of the amounts seized, it is difficult to understand the auditor’s expectations with respect to the meeting or, at the very least, what she would have considered sufficiently credible explanations to warrant some investigative work being undertaken. ... However, since only the amounts of Can$794,445 and Can$61,840 that were seized at the Jewellery Store were initially considered in calculating the net worth differential of Mr. ...

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. ...