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Clearly, a better contractual approach might have been taken from the outset had the GST issues been properly considered prior to finalizing the Arrangement. ...

It would be considered a loss.   [11]       In the tax return that was filed for 2000, the Appellant did not report any income so it is not clear how “this return could give rise to the Appellant acquiring cash”. ...

All of this unreported income was considered to consist of taxable supplies that were subject to $20,311.54 in unremitted goods and services tax (GST), plus interest and penalties ...

Most of the investors testified and I summarized their testimony in case my findings of fact on this point are considered relevant if there is an appeal. ...

Marengère and Matossian communicated daily regarding everything that involved acquisitions and activities, including source deductions. [16]   [36]     As for the Appellant Amyot, he was a retired lawyer in his late sixties during the year at issue and should only be considered an outside director [17] according to the Appellant Matossian. ...

Jorgensen, [1995] 4 S.C.R. 55, and summarized them as follows: [44]       Finally, the Chief Justice concluded that in order to benefit from the defence of officially induced mistake of law, an accused must show that "she made a mistake of law, that she considered her legal position, consulted an appropriate official, obtained reasonable advice and relied on that advice in her actions ": ibid., at para. 36. ...

It should be noted that where property is acquired to satisfy a personal desire, it may reasonably be considered to have been acquired for personal purposes, even though the property was not used or used very infrequently for personal purposes. ...

Holders of Combined Interests may not be able to liquidate their investment; their purchase should be considered only by investors who are able to make long-term investments and who are able to accept the risks inherent in the breeding of horses.... ...

This exercise, as viewed by any reasonable person, would have to be considered redundant at best, was without any reasonable explanation and without evidence from any other person who might have prepared the other records ...

The tax advantage which is received from gifts is not normally considered a 'benefit' within this definition, for to do so would render the charitable donations deductions unavailable to many donors. ...