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Minister of National Revenue v. Robert P. Ouellette an John E. Brett, [1971] CTC 121, 71 DTC 5094

He made a rough calculation in his head, without reducing anything to writing, of the amount which Blauer might have received if he had been considered as a partner in the Sherbrooke and Boucherville contracts and conveyed this figure, which worked out to about $82,000, to his lawyers. ... He explained that he considered the preliminary contract and the whole project together, since unless there is something wrong with an engineer, in about 95% of the cases the engineer who prepares the preliminary plans gets the contract. ... The judgment of the Tax Appeal Board found that the fees relating to the civil action brought by Blauer against them were a deductible expense but that the same did not apply to the criminal: cases and the libel action which were considered to be personal expenses of Brett and Ouellette. ...

Frederick Franklin Worthington v. Attorney-General of Manitoba, [1935-37] CTC 193

Moreover, the Privy Council considered that the Dominion Income Tax Acts were not discriminating statutes. ... In other words, is he, as far as his wages are concerned, to be considered as a free agent who can refuse to work? ... In this view, this appeal could be maintained, even if this Court considered itself bound by the rule stare decisis. ...

12 December 2012 Internal T.I. 2012-0464411I7 - Indirect Benefit

However, we do not appear to have yet considered whether the fee that is entitled to the amortized deduction under paragraph 20(1)(e) will be limited and proportionate to the portion of the borrowed funds that are considered to "fill the hole" of capital (as described in the preceding paragraph) or if no proration will apply to such a fee. ... This provision has not been considered often but, in somewhat similar circumstances quite long ago, was decided in favor of the taxpayer. ... Accordingly, it is our view that 105(1) would not be considered favorably as a ground for including a foregone interest benefit in the income of Mr. ...

12 October 2001 Internal T.I. 2001-0104217 - LEAKY CONDOMINIUMS

(rented property) could all be considered deductible as current expenses on account of repairs and maintenance. ... Otherwise, the costs are considered personal and living expenses which are not allowed any deduction under the Act. ... However, the courts have identified a number of factors that should be considered in making such determinations. ...

23 January 2008 Internal T.I. 2007-0258011I7 - QSBC Shares - Partnership Interest

In the case of a partnership, the employees are considered employees of the partners collectively, but not of any of them individually. ... However, Aco's business would not be considered to be a SIB if Aco satisfies one of the two mentioned conditions. ... Accordingly, for the purpose of determining whether Aco's rental operations are a SIB, Aco is not considered to employ the employees of the partnership of which it is a partner, since such employees are considered to be employed by the partners collectively. ...

25 March 2004 Internal T.I. 2002-0134201I7 - Foreign accrual tax-timing of Deduction

It was our conclusion that the total tax paid for the three years that should be considered FAT would be 300/620 of the total tax. The tax paid in year 1 clearly related to Fapi and would be considered FAT. ... Clearly the threshold required for an amount to be considered "paid" is even higher. ...

22 October 2010 External T.I. 2010-0380821E5 - Business Investment Losses and Bad Debts

Otherwise, where a portion of a debt can be considered uncollectible, this portion is not considered to be a bad debt for the purpose of section 50 even though accounting practice may require a write-down to realizable value. Where an amount owing by one debtor consists of more than one debt, each debt is considered separately in determining the extent to which the above comments apply. ... The Income Tax Act does not prescribe factors to be considered in assessing the collectibility of a debt. ...

30 September 2010 External T.I. 2010-0373951E5 - Wind energy conversion system

Where a taxpayer cannot be considered to have acquired a particular property for the purpose of earning income, the property would not be eligible for inclusion in any CCA class. ... In this regard, a property will not be considered to have been used for any purpose where it is new at the time that it is acquired. ... However, a property that is used regularly by the vendor for demonstration purposes is considered to have been used by the vendor. ...

10 March 2011 External T.I. 2010-0387251E5 - Clergy residence

" In our view, the Centre is not considered a parish or a diocese, for the purpose of paragraph 8(1)(c). ... Therefore, in your situation, in order for you to satisfy the function test as you assert, it needs to be determined whether you can be considered to be 'in charge of or ministering to a congregation'. ... Chaplains in hospitals, jails, the armed forces and other such organizations are generally considered to minister to congregations. ...

8 September 2010 External T.I. 2010-0369311E5 - Transactions with a Delaware LLC

In other words, a LLC registered in the state of Delaware, United States is considered a corporation for all purposes of the Act. ... For example, if the taxes paid are considered paid by US LLC, then Mr. ... On the other hand, if the taxes are considered paid by Mr. A, then Mr. ...

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