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He considered this to be a high risk earnings stream given the dependence on so few clients. ... However, a risk free rate of return is considered to be 8.5%. Therefore Mr. ... Again this presented a high risk factor which was not properly considered by Mr. ...

He also considered the future earnings method set out in schedule H of Exhibit A-l. ... However, a risk free rate of return is considered to be 8.5%. Therefore Mr. ... Again this presented a high risk factor which was not properly considered by Mr. ...

  [24]          I do not believe the appellant's interpretation of the facts can be considered unreasonable. ... The CRA auditor submits that the appellant did not live in the house in question or did not live in it long enough for it to be considered her principal residence. ... A secondary residence may be considered a principal residence under the legislation. ...

To be considered a "small business corporation", Homebank would have to be considered an "active business". ... " [29] The term "principal purpose" has also been considered in the tax literature. ... The "principal purpose" of Homebank, as an entire entity, must be considered. ...

To be considered a “small business corporation”, Homebank would have to be considered an “active business”. ... The term “principal purpose” has also been considered in the tax literature. ... The “principal purpose” of Homebank, as an entire entity, must be considered. ...

Again, the examples given in IC 92-2 are not meant to be exhaustive. [11]            The following factors were considered by Ms. ... In that case, one of the factors considered by the decision-maker was that the applicant did not dispute his liability. ... Bemister can one find a statement that the issue of "undue delay" was considered, I am satisfied that this submission is not valid. [25]            It is correct to say that amongst the factors listed as considered in the Asher affidavit or the Bemister affidavit one cannot find the words that the issue of undue delay was specifically considered. [26]            I am satisfied that the issue of undue delay was implicitly considered for otherwise it would not have been necessary for Ms. ...

Each paired Partnerco and Serviceco were considered to be associated with each other by virtue of common control (s. 256(1)(b) of the Act). However, the pair was not considered to be associated with any other pair. ... Instead, the Court should have considered the purpose of the separate existence of two or more corporations. ...

Counsel for the appellant considered that the appeal for the 1967 taxation year was invalid because it was from a nil assessment for that year, and asked that it be quashed. ... These loans made by the company to its customers might conceivably be considered as expenditures made by the company for the purpose of earning income from a business, but the advances made by the appellant to Waite, Reid and Company Limited cannot by any standard be considered as general expenses incurred by the appellant for the purpose of earning income from a business. ... Just as the appellant cannot be considered as operating an overall brokerage business independently of the companies incorporated for that purpose, the appellant cannot be considered as carrying on a loaning business independently of Waite, Reid and Company Limited because there is nothing in the evidence which indicates that the appellant made any loans other than to Waite, Reid and Company Limited in which the appellant is the principal shareholder. ...

To the contrary, the list of factors in Rule 400(3) inform the genus or class of matters that may be considered under Rule 400(3)(o), but does not otherwise restrict it: Walker v. ... Rather, settlement proposals or offers that do not meet the conditions of Rule 420 may be considered under Rule 400 in making a costs award: Dimplex North America Ltd. v. ... In both, in making costs awards, the Federal Court considered offers to settle that the Federal Court described as not “formal or substantive enough to satisfy Rule 420”. ...

Smeele generated through the operation of an Airbnb could be considered self‑employment income rather than rental income – the latter not qualifying as income to meet the minimum income threshold requirements of the Act. ... Smeele arguing, as he did before the Officer, that he considered his income from his Airbnb to be self-employment income based upon Interpretation Bulletin IT-434RSR, which was clearly before the Officer when he or she rendered the decision. ... Smeele states that on the basis of his reading of Interpretation Bulletin IT‑434RSR, he only had to list such extra services for their Airbnb property to be considered a business, and for the income from that property to be considered self-employment income rather than rental income. ...