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This was his main focus, although he also argued that the 1995 letters could be considered a re‑statement of the original 1990 agreement, or they could actually be viewed as standing on their own as an agreement.   He alluded to the fact that those letters might be considered as a recommencement of the 1990 agreement.   ... They suggest that, and are consistent with my conclusions that, the Appellant no longer considered that this 1990 agreement governed his circumstances as they existed subsequent to 1995.   ...

The IAD Decision [8]   The heart of the IAD’s decision is contained in the following paragraphs: [15]   The panel finds that the acts that are attributed to the MASSOB, namely the hijacking of tanker trucks, the attack on police stations and the attacks on government staff conducting a national census fall within the ambit of Section 34(1) (b) of the Act as they are all considered acts of subversion as defined by the courts in Canada. ... The panel believes that the Court’s acceptance of the concession that the MASSOB was involved in the high jacking of oil tankers is a strong indication that the court believed that there were reasonable grounds to believe that the MASSOB high jacked oil tankers in Nigeria. [12]   The IAD also considered the IAD decision in Benneth v Canada (Public Safety and Emergency Preparedness), 2013 CanLII 65198 (CA IRB) [Benneth]. ... In essence, reasonable grounds will exist where there is an objective basis for the belief which is based on compelling and credible information: [citation omitted]. [26]   It is also true there is a rebuttable presumption that the IAD considered the totality of the evidence. ...

Obviously, neither was before the IAD when it considered the appeal.   The affidavits supplement in some material respects the information that was considered by the IAD.   ... This finding was also reasonably open to the IAD on the record before it. [27]   It is not my role to re-weigh the individual factors considered by the IAD or to second-guess the IAD’s overall assessment of how the balance finally settled.   ...

Gill’s statement regarding his treatment in India and stated that he considered Mr. ... Gill’s specific concerns, I am satisfied that the Officer considered Mr. ... This shows that the Officer read and considered the declaration.   Therefore, I cannot conclude that the Officer “ignored” Mr. ...

An impairment is considered prolonged only if it has lasted or may reasonably be expected to last for a continuous period of at least 12 months. ... Only the nine activities described in the six subparagraphs of paragraph 118.4(l)(c) of the Act are to be considered. ... Not being able to work or to do one’s grocery shopping are not considered to be basic activities of daily living. ...

With respect to his qualifications in scuba diving, the appellant explained that he undertook various training courses relating to scuba diving and is considered a qualified scuba diving instructor. ... Justice Dickson emphasized that there are criteria to be considered in determining the issue at bar, these factors are not determinative of the question in and of themselves and merely serve as a guideline. ... The larger costs incurred by the appellant in the acquisition of specialty camera and related equipment which he contended was vital for his underwater photography would not be considered as items to be expensed. ...

In 1980 Mamo realized he required more office space and expansion of the premises was considered by Mamo and Wright. ... The offer was considered to be too low and was swiftly rejected. At approximately that same period of time Mamo had pretty well made up his mind” to merge and to move. ... I flatly reject as patent nonsense that he would permit Wrison to incur a sizable capital gains tax simply to accommodate three newly found fishing friends in some marginally considered business. ...

I am not able to agree with either submission. [12] In my assessment, the decision-maker considered all of the evidence before her that may have affected the ability of Mr. ... What scant evidence there is in the record was, in fact, considered by the decision-maker. [16] Lastly, Mr. ... The proportion of the interest component was only one of the factors this Court found to be relevant and not considered. ...

In order to determine whether a debt consisting of a salary is situated on an Indian reserve, the place of residence of the employer, who owes the salary (or other type of contractual debt), must be considered. 4. ... Income earned on a reserve by an Indian is considered exempt. Income earned away from the reserve is taxable. ... Some of the types of income may be classified as follows: (i) Salary and wages are considered to be earned where the services are performed. ...

Lo testified that she reviewed the correspondence with the appellant and was unable to find any documents referring to the March 20, 2017 redetermination that could be considered a notice of objection. [5] The situation regarding the 2016 base taxation year is different because the CRA considered a letter from the appellant dated November 15, 2018 a valid notice of objection to the October 20, 2017 redetermination. [6] Following a change in the appellant's income, the Minister made a notice of reassessment on October 20, 2017 regarding the 2016 base taxation year pursuant to which the appellant's CCB amount was reduced from $15,694 to $13,866, a $1,828 reduction. [7] In determining the appellant's entitlement to the CCB for the 2016 base taxation year, the Minister took for granted the following facts (the references and data relating to the 2015 base taxation year and the 2015 taxation year were intentionally omitted): a) the appellant has three children:- A, daughter born in 2003- H, daughter born in 2004- M, son born in 2014 b) during the years at issue, Abdellah Kidaei was the appellant's spouse; c) during the 2016 taxation year, the appellant's income was as follows: Year 2016 UCCB (Universal Child Care Benefit) $1,680 Employment earnings $2,080 Scholarship $11,459 Less:-Tuition fees ($1,342)-Basic scholarship exemption ($500)-Child care expenses ($1,386) Total income $11,991 d) Child Care Benefits for the 2016 base taxation year were based on the family income of the appellant and her spouse (net of UCCB) for the 2016 taxation year, which are as follows: [Blank / En blanc] 2016 2016 Net income ($) Reported Assessed Appellant $2,374 $11,991 Appellant's spouse $37,234 $37,234 Less: UCCB ($1,680) ($1,680) Family income (net of UCCB) $37,928 $47,545 [8] The main difference in the computation of the appellant's income for the 2016 taxation year is attributable to the tuition fees that she incurred in 2016 and the tax treatment of the $11,459 scholarship that the appellant received from the Government of Quebec to enable her to continue her studies in order to obtain an early childhood education certificate at the Université du Québec à Montréal. [9] The CRA considered the appellant to be a part-time student completing a specified educational program. [10] The appellant considered herself a full-time student because, in addition to the hours that she spent in class at the university, she had to complete internships at daycare centres with children aged five and under. ... Limitations of scholarship exemption (3.1) For the purpose of determining the total in paragraph (3)(a) for a taxation year, (a) a scholarship, fellowship or bursary (in this subsection referred to as an "award") is not considered to be received in connection with the taxpayer's enrolment in an educational program described in subparagraph (3)(a)(i) except to the extent that it is reasonable to conclude that the award is intended to support the taxpayer's enrolment in the program, having regard to all the circumstances, including the terms and conditions that apply in respect of the award, the duration of the program and the period for which support is intended to be provided; and (b) if an award is received in connection with an educational program in respect of which the taxpayer may deduct an amount by reason of paragraph (b) of the description of B in subsection 118.6(2) for the taxation year, for the immediately preceding taxation year or for the following taxation year (in this paragraph referred to as the "claim year"), the amount included under subparagraph (1)(n)(i) in computing the taxpayer's income for the taxation year in respect of the award may not exceed the amount that is the total of amounts, each of which is the cost of materials related to the program or a fee paid to a designated educational institution in respect of the program, as defined in subsection 118.6(1), in respect of the claim year. ... Therefore, the appellant was eligible for an education credit under paragraph 118.6(2)(b) based on a $120 amount for each month during which the appellant was enrolled at a "designated educational institution" in a "specified education program" and spent not less than 12 hours per month on courses in the program. [17] Accordingly, I find that: the appellant did not attend "UQAM" on a full-time basis; she was not enrolled as a full-time student at UQAM in 2016, and she is therefore not entitled to the tuition tax credit, nor the education credit for full-time studies. [18] In my opinion, only objective criteria, such as course and internship hours and the hours spent on program course work, should be considered in determining what constitutes full-time student status. [19] Regarding the computation of the CCB claimed by the appellant for the 2016 base taxation year, the Minister had grounds to disallow the $1,827 credit. ...