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Any material prepared or considered by the Minister or the [CRA] in relation to the decisions to issue to the [NIR] and to publish this notice in the Canada Gazette; and 3. ... As noted most recently by the Supreme Court, the Minister’s “decision must be considered reasonable if its conclusions fall within a ‘range of possible, acceptable outcomes which are defensible in respect of the facts and law’” (Mouvement laïque québécois v. ... According to the Appellant, the “complete record” consists of all documents and materials available to the Appeals Directorate and all documents and materials actually considered by the Appeals Directorate in making the Confirmation Decision under appeal. ...

Canada (Attorney General), 2001 CarswellNat 1262, where Sexton J.A. considered subsection 165(3) of the Income Tax Act that requires the Minister to act “with all due dispatch” upon receipt of a notice of objection: [13] The meaning of the phrase "with all due dispatch" has been considered by both the Tax Court of Canada and this Court. ... In any event, the UPS decision was later considered and distinguished by this Court in A OK Payday Loans Inc. v. ... Certainly the Minister had encouraged the Appellant in February 2014 when the NPR application was denied to submit a NRRPR application; signalling (sic) that the Minister considered that the Appellant might well qualify for that rebate. ...

George, on the basis of it being “self-serving” and on the basis of the credibility findings made before it was considered. ... Nonetheless, the Board failed to indicate, how, if at all, the psychological report was considered when making its credibility finding. The Board was obliged to do more than merely state that it had “considered” the report. ...

Caponi's testimony similar to the testimony considered by the late Chief Judge Garon in McKeown. ... Once again, I adopt the same analysis that Chief Judge Garon adopted in McKeown:   [403]  Based on the parties' arguments and the evidence, the appellant cannot be considered to have been a limited partner in the two partnerships in question under the Income Tax Act unless subsection 96(2.4) of the Act is applicable to him. ... In order not to be considered a passive specified member, [41] Mr. Rouleau would have had to prove, on a balance of probabilities, that he was engaged in Cablotel's activities on a regular, continuous and substantial basis ...

Indeed, if the scheme considered in the Duke of Westminister was used in Canada today it "would probably be caught" by GAAR: Peter W. ... This inquiry involves taking two smaller steps. [36]       First, a court must determine "if it may reasonably be considered that the transaction would not result directly or indirectly in a misuse" of the provisions of the Act. ... " [40]       Thus, if the scheme may reasonably be considered not to result directly or indirectly in a misuse or an abuse, GAAR does not apply: in effect, the taxpayer is given the benefit of any doubt. ...

Iaconetti's testimony cannot be considered reliable since he was rather vague and inaccurate. ... In my opinion, the evidence submitted by the appellant on this subject did not create a sufficient degree of probability to be considered a prima facie case. ... Iaconetti's testimony cannot be considered reliable because he was deliberately vague and unclear. ...

The appellant argues that the object and purpose of the Act must be considered. ... The Decision Under Appeal 8 The Tax Court Judge considered the application of subsection 55(1) to the case at bar and found that it did not apply to reduce the losses claimed by Nova. ... </p>] 66 All the circumstances must be looked at to appreciate if the taxpayer “may reasonably be considered to have...” ...

Although the worker's name appears on the corporation's certificate, the appellant considered him an employee ... A contract of employment is a contract by which a person, the employee, undertakes for a limited period to do work for remuneration, according to the instructions and under the direction or control of another person, the employer.  ...In my view, the $500 he received was a non‑recoverable advance on the profits that the DN partnership might make.  ...Unlike a joint-stock company, a partnership is not considered to be a person separate from its partners. ... Somers" Deputy Judge Somers   CASES CONSIDERED   L'Espérance (c.o.b. ...

POINTS AT ISSUE [2]                The points at issue are the following: (1)       Should the new evidence the appellant wishes to submit be considered by the Court? ... ANALYSIS Should the new evidence the appellant wishes to submit be considered by the Court? ... Marrazza and the Laurentian Bank, in case No. 500-17-004262-989. [6]                The usual test for determining whether new evidence should be considered was laid down in [1964] S.C.R. 122 "> Dormuth v. ...

DEFENDANT'S ARGUMENTS [15]      The defendant mentioned that the plaintiff's case was considered pursuant to the discretion conferred in s. 152(4.2) of the Act, and that the decision of February 15, 2001, was made in that context. [16]      The defendant asked the plaintiff's employer what its policy was on payment of automobile expenses. [17]      The employer informed the defendant that the plaintiff was unionized and he was paid a standard allowance under the collective agreement between the employer and his union. [18]      The defendant added that it was not up to her to assess all the conditions of the collective agreement, and unless the information received from the employer was completely unreasonable it was not this Court's function to intervene. [19]      Further, during the course of negotiating a collective agreement, it is very probable that the union will emphasize some areas more than others in order to benefit its employees. [20]      As to the decision in Yvon Royer v. ... Moreover, looking carefully at the sections of the collective agreement applicable here, I note that a remedy existed which the plaintiff could have used if he considered that the payment of the standard allowance for his travel was unreasonable. ... An allowance for travel expenses is not considered unreasonable merely because the employee's total expenses for business travel exceed the total travel allowances received in the year. ...