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In addition, even if these loans existed, they were not contemplated at the time of transfer of the interest in the Property, and thus, they cannot be considered as part of the consideration given by Ms. ...

This Court considered pa r agraph 8(1)(f) and wrote: [7] P aragrap h (1)(f) …refers to amounts expended. ...

In arriving at the answer to that question, I have considered the assumptions and the evidence under each criterion in turn. 1. ...

Doherty considered various offshore markets that SLAC might consider entering, and provided his recommendations to Mr. ... Furbert also signed an authorization for personal information also dated December 18, 2006, a date before she was even considered for the position and while the offer was pending to Ms. ...

They cannot succeed in that purpose unless they are considered to be mandatory requirements and strictly enforced. ... The Queen, 2015 TCC 182, [2016] GSTC 53, Associate Chief Justice Lamarre stated as follows: [28] As stated above, when there is an issue of gross negligence, the taxpayer’s conduct should be considered, especially if it must be determined whether the taxpayer was wilfully blind. ...

Likewise, there was no evidence to support the allegations in paragraphs 6(k), (l), (m) or (n), nor the conclusion reached in paragraph 6(o), even if the conditions referred to therein should be a factor to be considered in the contract of service argument. ... Some of the presumptions may have been rebutted and some may even have been supportive of the Appellants’ position but the ultimate result is that the significant allegations detrimental to the Appellants’ positions have not been rebutted and indeed could not have been rebutted without the evidence of the “Payor”. [413] Taken in isolation, the payment of wages in cash may not be significant, but when considered in light of the allegations of the Respondent in the Reply and in light of the failure of the Appellants to produce any corroborative evidence of payment, that fact is of significance. ...

She considered herself to be the bookkeeper and the secretary and MacNeil was managing the office and doing estimates. ... " This, however, is evidence that the term "directors" was considered by MacNeil and he made it clear throughout that the Appellant was a party to mostly all of these meetings if not all of them and the same information was made available to the Appellant from their lawyers, accountants and auditors as was made available to MacNeil. ...

Although Cattanach J. expressed the caution that his words did not constitute an “exact” definition, the extent to which his words have been adopted in the jurisprudence without change over some thirty years suggests that his approach, although not necessarily exhaustive, is now considered to be the working definition. [38] [42] In the same decision, Justice Rothstein went on to observe that: [17] In applying the Henderson definition of fair market value, the first step is to accurately identify the asset whose fair market value is to be ascertained. ... While these incentives appear to be an extension of the existing rules for charitable giving, they must be considered independently of the tax programs which support charitable giving. ...

Indeed, it could be said that in adopting the exception that the Respondent seeks to rely on in this motion, these cases considered that the public interest in having full access to material in order to have a full and fair trial outweighed the public interest in promoting settlement, particularly when there would be no prejudice to the party relying on the privilege since the communications could not be used against them for the same conduct that was the subject of the settlement. ... It says tax motivation does not need to be singled out as something that needs to be specifically pleaded, since tax motivation is just one of many reasons why CIBC’s deduction could be offside with either paragraph 18(1)(a) or s. 9. [263]    The Respondent also points to McKesson Canada Corporation v The Queen, [125] which said that tax motivation may be part of the factual context that needs to be considered for paragraphs 247(2)(a) and (c) of the Act, both of which are still in play in the tax appeals. [126] [264]    In my view, the questions on allocation are generally relevant for the reasons the Respondent proposes. ... McKesson Canada Corporation noted that tax motivation may be part of the factual context that needs to be considered for these subsections, and given the low relevancy threshold associated with discovery, I find that these questions are generally proper and should not be broadly deemed to be irrelevant. ...

In determining the projected service bureau fees, Sean O’Dea considered the anticipated sales in Florida and Georgia. ...