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Some of the additional factors that might be considered were identified by Justice Bowman in Continental Bank Leasing Corp. v. ...

Counsel for the appellants acknowledged that the use of the condominium may be considered to have an element of personal use and benefit. ...

In either case the Court considered the language of the statute to apply. ...

At first glance, the difference between the two values should be considered as capital gain taxable in the year it was received, in 1982. ...

This is said at page 18 under the heading “Deferred Foreign Exchange Gain”: This suggests that if the debentures could be considered as capital debt obligations, the gain when realized at maturity should be reported on account of capital. ...

Faucher felt ill at ease with this arrangement, which he considered presented him with ethical problems. ...

Timeliness [46] As indicated in Continental Bank Leasing, one of the factors to be considered by the Court, when determining whether a proposed amendment would serve the interests of justice, is the timeliness of the motion to amend. [33] Given that the Respondent had included paragraph 51 in her Reply in Chad II, which was filed on May 27, 2019, the current Motion to amend (so as to add proposed paragraph 39.1 and other provisions), notice of which was filed June 29, 2021, was anything but timely. ...

Szuch in 2008 as “Loan as per Receipt Book”. c) disallowed as a liability the $62,000 loan in 2008; d) summarized the personal expenses for the relevant years; [23] e) added $1,455 as “Net Rent Income” in 2007 as owners of 3 Robin Hood; [24] f) increased each Appellant’s income by $33,273 and $158,212 in 2007 and 2008, respectively, as unreported shareholder benefits conferred on them; and g) imposed penalties in the amounts of $9,129.22 and $27,973.05 for 2007 and 2008, respectively, on the unreported income. [39] By letter dated March 20, 2015, the Appellants requested that the Minister reconsider the amount of Advanced Funds included in the calculation, and submitted that 80% of the Advanced Funds should have been considered impaired in the relevant years. [40] On March 31, 2015, the Minister confirmed the reassessments and penalties for 2007. ...

This was the same issue considered by the Court in the Wheeler case. The Appellants there argued that both “discovery” and “accumulation” should be given their plain and ordinary dictionary meanings such that, at most, clause (ii.l)(A) adds a requirement that the well have the ability to produce petroleum or natural gas (irrespective of from what pool such production is attained). ...

You can ask him questions about what he looked at and what he considered, but it’s improper to ask us how – for our evidence on certain points. ...