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Guests on a magazine program, or the subjects of biographical documentaries, are not considered performers for certification purposes ... Also considered to be the subject is the founders and directors of the website, Robert Luciano Hintze and Greg Hodge. ... Those submissions were fully considered.   [35]            To address the issues in particular.   ...

I have considered the application of these two cases to the case at bar, and must, with respect, come to a different conclusion than that of Robertson J.A.      ... Certainly, it is not contentious that in order to properly be considered active business income, interest must come from an asset that is risked or employed in the course of the business.      In this case, however, the issue is not whether income in the fund is properly considered "active business income" for the purposes of the Act. ...

OVERVIEW OF THE THIRD CONDITION [8]   The Act tells us when an activity of daily living is to be considered markedly restricted. ... That is, given the detail he provided with respect to the first of these, he might have considered answering No because Ms.  ... THE LAW [40]   A number of cases have considered the availability of the DTC in the context of mental impairments. ...

The section is cast in terms of a double negative, stating that the GAAR does “not apply to a transaction where it may reasonably be considered that the transaction would not result directly or indirectly in a misuse... or an abuse”. ... Canada, 2009 SCC 1, [2009] 1 S.C.R. 3, the Court considered in greater detail the phrase “directly or indirectly”, as used in subsection 254(4) of the Act. ... (reasons, paragraph 65). [73]   Finally, the Court observed that while the Explanatory Notes to the Budget “describe the type of transactions considered offensive” they “add no additional information regarding when or how far into the future an advantage (i.e., an increase in value) will be considered as attributable to such transactions.” ...

Repositioning the Mafi trailer, prior to actually lifting the cargo onto the truck, was considered part of the loading process, and thus the road leg. [31]   Dr. ... Kienzle, I have considered each party's argument that the opinion of the other's expert, when applied to certain hypothetical fact scenarios, would generate absurd results. ... Schwampe raises the facts considered in the 2007 Decision, involving pre-loading damage to the cargo on the Mafi trailer, but hypothesizes a variation in which the truck that was awaiting loading of the cargo was a rogue, unauthorized by the multimodal carrier. ...

Carpenter’s request for relief was a reasonable exercise of the Minister’s discretion and a fully justified outcome. [5]   I have carefully considered Ms. ... She remained responsible for filing correct and complete tax returns. [18]   The Minister’s delegate then considered whether CRA delay had prevented Ms.  ... Carpenter in order to resolve her tax position and considered the 2018 determination that the Minister’s 2004 assessments for the 1999-2001 taxation years were incorrect. ...

Consequently, if the use of a corporate asset is the feature to be considered in the application of paragraph 54(f) it must be in excess of a ratio 50 per cent of the total use of that asset. ... The respondent also ascribed to Mailhot flying time with respect to business trips which the company had considered corporate use. ... The flaw in the respondent's assessing process, if only the flying time is considered, resides mainly in his approach to the training time treated as personal use of Mailhot. ...

Mr Bassett considered that the opportunity to own a television station in Windsor presented a challenge to his company. ... The reply was that the purchase price had to be considered so that the loss had to be offset by the income in the purchase price. ... As mentioned, all things being considered, I hold that the appellant was in partnership with St Clair in the operation of CKLW TV in Windsor. ...

It is considered to be “one of the nicest farm in the valley.” Most of the work was completed by 1991. ... He considered himself to be in the general practice of dentistry and does a lot of denture work. ... He worked six to seven hours a day and considered that to be a normal dentist’s practice hours. ...

Findings It is difficult to take seriously any contention that the development of the land itself was considered as a real prospect by the investors. ... The appellant’s declared intention of purchasing the properties as an investment in rental properties must, of course, be considered by the Board. ... If property is acquired when there is no business even though one possibility in the mind of the purchaser is to use the property as the capital asset of a proposed business—or the purchaser has not considered how he will use it—a re-sale may be the consummation of a venture in the nature of trade. ...