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Results 4311 - 4320 of 5747 for consideration
TCC

Lavigne v. The Queen, 2014 DTC 1018 [at at 2615], 2013 TCC 308 (Informal Procedure)

For 2007, the appellant drove 5,130 kilometres, to which 1,800 were added to take into consideration the six reimbursements paid by the employer (6 x 300 kilometres), for a total of 6,930 kilometres driven for business purposes out of a total of 15,633 kilometres (or 28,388 kilometres x 201/365 days). ...
TCC

Pantorama Industries Inc. v. The Queen, 2004 DTC 2536, 2004 TCC 256

Because of Snowcap's involvement in the retail property market, it was aware of new property developments coming available 4 to 5 years in the future and could pass this information on to the Appellant for its consideration. [13]     Mr. ...
TCC

DRL Group Ltd. v. M.N.R., 2006 DTC 3113, 2006 TCC 331

Walker (1858), 27 L.J.M.C. 207, 208: It seems to me that the difference between the relations of master and servant and of principal and agent is this: A principal has the right to direct what the agent has to do; but a master has not only that right, but also the right to say how it is to be done. [6] [15]     Ownership of Tools           In applying this test the Court looks at the tools or assets used by the Worker. [16]     Chance of Profit and Risk of Loss           In an employee/employer relationship it is the employer who bears the burden of profit or risk of loss; the employee does not assume a financial risk as he receives the same wage no matter what the employer's financial situation. [7]           It should also be noted that in Wolf, Desjardins J.A. expanded the notion of risk to factors beyond financial risk: In consideration for a higher pay, the appellant, in the case at bar, took all the risks of the activities he was engaging in. ...
TCC

Morisset c. La Reine, 2008 DTC 3864, 2006 TCC 483

(QL); Marie-France Bich, "Le professionnel salarié: considérations civiles et déontologiques", in Journées Maximilien-Caron (1994) (Montréal: Themis, 1994), at page 45; Pauzé v. ...
TCC

Tétrault v. MNR, 92 DTC 2240, [1992] 2 CTC 2787, [1992] 2 CTC 2125, [1992] DTC 2235 (TCC)

The present sale is made for and in consideration of the amount of TWENTY- FIVE THOUSAND DOLLARS ($25,000) on account and, deducted from which amount, the Vendor acknowledges receipt, upon execution hereof, of FIVE THOUSAND DOLLARS ($5,000). ...
TCC

Bernier v. The Queen, 2004 DTC 3235, 2004 TCC 376

It is necessary to adjust the amount of the losses, taking into consideration the specific exchange rate between the U.S. and the Canadian dollar in effect in 1992, at the time of the drawdown from the line of credit.  ...
TCC

Cameron v. Queen, 2011 DTC 1166 [at at 914], 2011 TCC 107

Tardif J. stated:   15        Although the appellant's submissions were unusual and even surprising, they were neither far-fetched nor unreasonable enough for it to be concluded that he made a wilful default or mistake with the intent to escape from his Canadian tax obligations.   16        Firstly, he expressed his objection, and secondly, he took initiatives to show that his allegations had merit, while taking into consideration the fact that certain income, specifically, pension income paid to a citizen who lives in a country other than the one that pays the pension, is not taxed ...
TCC

Palardy v. The Queen, 2011 DTC 1188 [at at 1050], 2011 TCC 108

Tardif J. stated:   15        Although the appellant's submissions were unusual and even surprising, they were neither far-fetched nor unreasonable enough for it to be concluded that he made a wilful default or mistake with the intent to escape from his Canadian tax obligations.   16        Firstly, he expressed his objection, and secondly, he took initiatives to show that his allegations had merit, while taking into consideration the fact that certain income, specifically, pension income paid to a citizen who lives in a country other than the one that pays the pension, is not taxed ...
TCC

David T. McDonald Co. Ltd. v. MNR, 92 DTC 1917, [1992] 2 CTC 2607 (TCC)

In consideration of the services to be rendered by McDonald, Status shall pay to McDonald the following compensation: (a) A fixed annual fee of TWENTY-FOUR THOUSAND DOLLARS ($24,000), payable at the rate of Two Thousand Dollars ($2,000) per month, in advance, the first payment to become due on the date that this agreement comes into force, and thus to continue on the same day of each month throughout the term of this agreement; (b) A further fee equivalent to ONE AND ONE-HALF PERCENT (1-1/2 of the gross selling price (less all discounts, returns and allowances) for all leather and vinyl footwear sold by Status directly or indirectly throughout the term of this agreement (d) Status will reimburse McDonald for all vouchered, reasonable and normal travelling expenses incurred by McDonald or its employees in the implementation of this agreement 6....this agreement is subject to prior termination by Status on thirty (30) days written notice to McDonald upon the happening of any one or more of the following events: (c) In the event that the gross sales of Status between July 1st, 1970 and June 30th, 1971, or any subsequent one-year period commencing on July 1st, and terminating on June 30th, throughout the term of this agreement shall be less than one million dollars ($1,000,000). ...
TCC

Parent v. The Queen, 2003 DTC 1002, 2003 TCC 509

.); ex parte Hooper ((1926) 37 C.L.R. 368 at 373): An "assessment" is not a piece of paper; it is an official act or operation; it is the Commissioner's ascertainment, on consideration of all relevant circumstances, including sometimes his own opinion, of the amount of tax chargeable to a given taxpayer. ...

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