Search - considered

Bonner, T.C.J. considered Pidskalny. In Black, Bonner J. made the following comment at page 1215: The Appellant cannot take shelter under subsection 227.1(3) by claiming that his actions met the standard of a reasonably prudent person who was ill-informed as to the requirements of the Act. ...

The position taken by counsel for the appellants to the effect that the wording of subsection 160(1) assumes such a requirement is even less acceptable given that in the instant case Benoît Montreuil Sr. effectively provided for the transfer of his property when alive by writing a will, which is considered a deed of gift of his property in contemplation of death to take effect after his death. ...

Counsel for the respondent considered that the facts set out in the aforementioned subparagraphs provide a sufficient basis for the conclusion that the parties were not dealing at arm’s length at the time of the transfer, that is, when the dividend was paid. ...

However, there is no doubt that for this period, the Appellant thought he was receiving his own money back and if either the Appellant or his accountant had, for even one brief second, considered these sums, it would have been shown as a return on capital. ...

It was the first time, the Appellant and his partners were involved in such a business investment and they considered it advisable to retain the services of the accountant. ...

The French version of paragraph 118.2(2)(/.2) adds an element to be considered when determining whether or not the renovations undertaken by Ms. ...

The allowable amount for services of counsel is stipulated in paragraph 1(1)(J) of Schedule II, Tariff B of the Rules: 1(1) The following amounts may be allowed for services of counsel: (J) for conduct of the hearing for each day or part thereof, Class B: $1000 The reasons of counsel for the Appellant which were considered by the Registrar in the Certificate of Costs included: 1. ...

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. ...

Paulette made a comment in evidence to which I attach much significance: “For them, it has never been considered like work because it was family time together.” ...

His ruling is considered to be final and binding until it is reversed and Belchetz has not instituted any proceedings against it. ...