Search - consideration

Results 301 - 310 of 584 for consideration
SCC

Alworth v. Minister of Finance, [1978] 1 SCR 447

Although that case in one of its aspects concerned, as does the present one, the question whether a provincial statute had imposed its taxation within the Province or had unconstitutionally reached outside, it related to succession duty legislation and does not call for further consideration here. ... My conclusion, in rejection of the contention of the appellants, accords with that reached by Seaton J.A. speaking for the British Columbia Court of Appeal; and, indeed, his analysis of the Logging Tax Act and his consideration of the relevant case law relieves me of the necessity of [Page 453] enlarging my reasons in those respects. ...
SCC

Pfizer Co. Ltd. v. Deputy Minister of National Revenue, [1977] 1 SCR 456

Since the Official Languages Act requires that each version be read in the language in which it is written, the Board could not ascertain the meaning of the enactment under consideration, taking together the English and French dictionaries as if just one language was to be considered. ... In my view, the meaning of the enactment under consideration could not be ascertained by the Board as it did, taking together the English and French dictionaries as if just one language was to be considered. ...
SCC

Attorney General of the Province of Quebec v. Dame Margaret Joi Stonehouse, [1979] CTC 233

A life-rent constituted upon the life of a person who is dead at the time of the contract produces no effect, and the consideration paid for it, may be recovered back. ... Even if paragraph 46(1)(b) were to apply only to life insurance policies, there would be no incompatibility with the other provisions under consideration, especially subsection 26(1). ...
SCC

The Royal Trust Company, James Reid Sare, James Gemmill Wilson, Executors or the Estate of Agnes Henry Wilson v. Minister of National Revenue, [1968] CTC 224, 68 DTC 5158

This view, as to the intention of the father of the deceased, is formed by the appellants on a consideration of the directions appearing in the tenth clause of the will and of the provisions of the fifth clause of the deed of donation which they seek to interpret and rationalize in a manner consistent with the motives which, in their view, prompted the father of the deceased to so direct and provide. ... VI, c. 14, was determined on consideration of certain provisions thereof which differ, in substance, from their counterparts in the Estate Tax Act (supra). ...
SCC

Toronto College Park Ltd. v. R., 98 D.T.C. 6088, [1998] 2 C.T.C. 78

.), c.1) 9. (1) Subject to this Part, a taxpayer's income for a taxation year from a business or property is his profit therefrom for the year. 18. (1) In computing the income of a taxpayer from a business or property no deduction shall be made in respect of (a) an outlay or expense except to the extent that it was made or incurred by the taxpayer for the purpose of gaining or producing income from the business or property; (9) Notwithstanding any other provision of this Act, (a) in computing a taxpayer's income for a taxation year from a business or property (other than income from a business computed in accordance with the method authorized by subsection 28(1)), no deduction shall be made in respect of an outlay or expense to the extent that it can reasonably be regarded as having been made or incurred (i) as consideration for services to be rendered after the end of the year, (ii) as, on account or in lieu of payment of, or in satisfaction of, interest, taxes..., rent or royalty in respect of a period after the end of the year, or (iii) as consideration for insurance in respect of a period after the end of the year....; (b) such portion of each outlay or expense made or incurred as would, but for paragraph (a), have been deductible in computing a taxpayer's income for a taxation year shall be deductible in computing his income for the subsequent year to which it can reasonably be considered to relate;... ...
SCC

Bessie L. Shaw v. Minister of National Revenue, [1938-39] CTC 346

There is an additional consideration which ought not to be overlooked. ... Whatever considerations may have moved Parliament to enact clause (k) of subsection 1 of section 5 in 1930 and 1932, with reference to agreements to pay an annuitant certain sums during his lifetime, can have no bearing, it seems to me, upon the question as to what are proceeds of life insurance policies paid upon the death of the person insured, as mentioned in clause (b) of section 3. ...
SCC

Pioneer Laundry and Dry Cleaners, Ltd. v. Minister of National Revenue, [1938-39] CTC 401

Ryder, [1907] A.C. 420, at 423, 424, said that the justices there were acting " " administratively, for they are exercising a discretion which may depend upon considerations of policy and practical good sense—and they must, of course, act honestly. ... But that was a certiorari proceeding and the Licensing Act under consideration ‘‘expressly leaves” as Lord Loreburn observed, to the discretion of the justices whether they will grant licences or not to persons whom they deem fit and proper persons. ...
SCC

His Majesty the King v. City of Montreal, [1945] CTC 386

But, in order that the Company may be exempt from paying the taxes claimed by the City in the case now under consideration, it is not necessary that it should be either ‘‘an instrumentality of the Government, or an emanation of the Crown’’. ... Moreover, with due respect, the Regina judgment, although entitled to great consideration, cannot be looked upon as an authority in this Court. ...
SCC

Reference re Validity of Section 5 (a) Dairy Industry Act, [1949] SCR 1

That consideration was considered sufficient in Attorney General for Ontario v. ... Strikes and lockouts were prohibited pending the consideration of the Board. ... This statement must be construed in relation to its context and the legislation under consideration. ...
SCC

Canada (Minister of Citizenship and Immigration) v. Vavilov, 2019 SCC 65, [2019] 4 SCR 653

Relative expertise remains, however, a relevant consideration in conducting reasonableness review.                     ... Accordingly, a reviewing court may find that a decision is unreasonable when examined against these contextual considerations. ... Such decisions will sometimes involve complex technical considerations. ...

Pages