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It seems to me that all of the expenditures relating to the investigation of opportunities must be considered on the same footing. ... Thus supervision expenses, since they related to the management of the portfolio or assets, must be considered as incurred in building the structure of his business. ... I do not indeed feel that merely because the expenditure was made for the purpose of determining whether to bring into existence a capital asset, it should always be considered as a capital expenditure and, therefore, not deductible. ...

Pannett’s evidence was that in August or September 1986 Husky was advised by a representative of its major shareholder, Nova, (’’Nova") an Alberta corporation that a transaction respecting the Allarco shares was being considered. ... Positions advanced by the parties Both counsel advised no issues were being put forth as to whether paragraph 245(2)(a) is to be considered as a charging or a characterizing provision. ... The Minister’s assessed value of the benefit (1.e., the tax refund amount for 1984 less Husky’s outlays) rests upon hindsight which totally ignores the risks known, considered and acted upon in 1986 by the vendors and Husky. ...

Rae takes the rationale behind the GTS Program for granted as she argued this rationale has already been “canvassed, considered and rejected” in Ficek. ... The third proposed method is that she will undertake to publish the Notice of Proceeding in such publications considered as fair and appropriate by the Court. (2)                The Minister’s position [42]            The Minister submits that in assessing whether Ms. ... Matters to be considered (2) All relevant matters shall be considered in a determination of whether a class proceeding is the preferable procedure for the just and efficient resolution of the common questions of law or fact, including whether (a) the questions of law or fact common to the class members predominate over any questions affecting only individual members; (b) a significant number of the members of the class have a valid interest in individually controlling the prosecution of separate proceedings; (c) the class proceeding would involve claims that are or have been the subject of any other proceeding; (d) other means of resolving the claims are less practical or less efficient; and (e) the administration of the class proceeding would create greater difficulties than those likely to be experienced if relief were sought by other means. […] Règles des Cours fédérales, DORS/98-106 Par un membre du groupe 334.12 (1) Malgré la règle 302, une action ou une demande peut être introduite par un membre d’un groupe de personnes au nom du groupe, auquel cas la mention « Recours collectif — envisagé » est placée en tête de l’acte introductif d’instance. ...

                                 [16]            Parties are not considered to be dealing with each other at arm's length if one person dictates the terms of the bargain on both sides of the transaction. ... The Queen, [2001] D.T.C. 5093, to argue that he should be considered to have made his own decision based on his own economic interest and that there was no person or group of persons deciding to enter into the Software Agreement on the part of the partnership. ... He considered the Minister substantially successful because the appellant's claimed deductions were, according to his finding, cut roughly in half. ...

In that case, Major J. summarized certain important factors to be considered in determining whether a transaction in real estate is an adventure in the nature of a trade. ... The more closely a taxpayer's business or occupation is related to real estate transactions, the more likely it is that the income will be considered business income rather than capital gain. ... The following criteria should be considered: the profit and loss experience in past years, the taxpayer's training, the taxpayer's intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...

Minister of National Revenue, [1971] S.C.R. 1032, considered; Buckerfield’s Ltd. v. ... For these reasons it was likely to be the group which would in fact wind up the company if and when it considered it in its best interests to do so.   20.               ... Jackett P. considered s. 39(4)(b) and commented at pp. 302‑03:                      Many approaches might conceivably be adopted in applying the word "control" in a statute such as the Income Tax Act to a corporation. ...

Kirky added that his recommendation had to be reviewed and considered by at least three or four higher levels before being given final approval stating that the plaintiffs were associated with each other. ... Savino Cantatore felt hard- pressed by these difficulties he even considered selling his business unless he could make an arrangement such as that he subsequently made with his son Giuseppe. ... It further found that the evidence presented by the plaintiffs that they had not considered reducing tax did not in any way shift the burden of proof imposed on them by the Act. ...

While every case must be considered in its overall context, I see no reason in the case at bar to distinguish it from the Federal Court of Appeal decision in Rich ... The Respondent essentially wants me to find that on a balance of probability, the Appellant never considered that the worthless Debenture might someday yield a return. ... No other provisions of the Act had to be considered in terms of aiding or dictating a particular construction of that provision in the circumstances of that case. ...

Even if he were considered as being in the employ of Delsco since his salary was paid by it, this would not change the tax situation in the present appeal. ... Certainly, in corporation law a director is not an employee, being elected by the shareholders, whereas an officer is normally an employee appointed by the directors and usually a director himself, unlike a corporate secretary who would be considered as an employee and an officer but most likely not a director. ... One more matter remains to be considered, however, although it was not addressed by the parties. ...

The bonds in this case must, as respects the obligation of the railway company, be considered specialties, although the head office of the company is fixed by statute in Quebec; and, in view of the statute law applicable to the case, it must be held such a specialty has its situs in Ontario. ... Smith 25 were to be considered appropriate to debts (other than specialties and negotiable instruments) then the words “the place where it can be effectively dealt with” must be understood, as Mr. ... The bonds must, we think, as respects the obligation of the company, be considered specialties. ...