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The CRA, however, refused to assign the Applicant investigation casework due to her McNeil concerns. [13]   In a decision dated July 23, 2015, the Board considered the Applicant’s Suspension Grievance and her claim that her transfer to the SME was discriminatory (Lloyd v Canada Revenue Agency, 2015 PSLREB 67 [Second Board Decision]).   ... The remaining exhibits contain information that goes to merits of the previous proceedings, of which the Assistant Commissioner is expected to have considered. ... The Respondent further submits that the factual context in which the Final Grievance Decision was reached should be considered in assessing whether it was reasonable.   ...

Both parties agree that the appellant's return for the 1984 taxation year was not filed as required by Part I of the Act and therefore his 1984 taxation year cannot be considered for the purposes of section 119 of the Act. ... This concept, however, has been extensively considered in connection with the restricted farm loss provisions found in section 31 of the Act. ... I have considered the gross income, the net income, the capital investment, the cash flow and the personal involvement of the taxpayer. ...

Therefore the scope of the decision in this court must clearly be confined to what was actually considered. ... The decision is of interest to the determination of this matter because of analogous issues it considered. ... We have considered your analogy between aboriginal people and immigrant women as disadvantaged groups in society. ...

The taxpayers considered they had received an emolument as a result of paying a reduced fee for tuition but maintained the cash equivalent of the benefit had to be determined under the principle of marginal costing. ... Pratte J.A. at page 6325, explained that in determining the value of a benefit its cost may be considered. ... The appellants educate their children at BCS and it is the value of the benefit at BCS which is to be considered. ...

In his income tax returns, the appellant considered his activities in the real estate field as constituting a single business. ... I also considered another issue which appeared to underlie certain observations by counsel for the respondent. ... Having regard to the facts of the instant case, it is possible that the application of section 9 of the Income Tax Act should also be considered for the purposes of determining the appellant’s income gained from the business which he operated. ...

("Métro"), whereas the appellant had considered that the amount was the proceeds of disposition of eligible capital property and as such had included the sum of $36,560 in its income. ... Please take note that in the event of your acceptance hereof the undertakings given herein shall be considered an integral part of other undertakings already given or to be given in accordance with the policies of Métro or Épiciers. ... I therefore consider that the amount of $75,000 received by the appellant can reasonably be considered a payment made for the acquisition by Métro of rights in the appellant’s business within the meaning of subparagraph 12(1)(x)(viii) of the Act. ...

That the income from that transaction must be considered to be a capital gain within the meaning of the Income Tax Act. 19. ... That the income from this transaction must also be considered as a capital gain and not as income from a business. 26. ... While all of the above factors have been considered by the courts, it is the last one, the question of motive or intention which has been most developed. ...

Defendant submits that if there is nothing in the ITA, then the payment of the US$6,000,000 should be considered taxable income as being income derived from a business. ... From the facts in this case, I am satisfied that the moneys received by Mohawk were not paid as compensation for moneys which should have been paid pursuant to a business and should not be considered as income. ... The facts only indicate that the money was paid as damages to prevent a lawsuit that could have been considered an embarrassment to Phillips and nothing more. ...

Decision Under Appeal [11] Prothonotary Kevin Aalto [the Prothonotary] considered and dismissed the Minister’s motion to strike, in the Decision that is under appeal in this motion. ... The Minister relies on McCain Foods Limited v JR Simplot Company, 2021 FCA 4 [McCain Foods] at para 65, which considered the question of the Federal Court’s jurisdiction in relation to a third party claim in the context of a piece of patent litigation. ... I agree with Iris’ position that, consistent with the statutory purpose of the CEWS program, which is to enable Canadian employers to retain employees while coping with the commercial impacts of the COVID-19 pandemic, Iris should not be deprived of an opportunity to have its requests for relief considered in an expeditious manner. ...

Since the subject site contains an area of 174,240 square feet, the total value is: $1,045,440 In order to verify the value arrived at through the square foot method, we also considered the property on a price per suite basis. ... Therefore, any shrinkage in the value of the land and building considered as a property, or a unit, must be seen as a shrinkage in the value of the building. ... There is then the testimony of the purchasers that it was not considered at all by them. ...