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FCTD

X v. Canada, 2022 FC 660

As described by Justice Noël in Brar, the appeal is “robust.” [63] I acknowledge that |||||||||| ’s Charter and constitutional arguments deserve consideration and note that similar issues have been raised before this Court in other proceedings. ...
TCC

Tedesco v. The King, 2023 TCC 114

Jones (19 August 2014) Questions 183 to 205 inclusive and answers. [24] The latter involves considerations involving the rule against hearsay and exceptions to that rule. ...
TCC

Stackhouse v. The King, 2023 TCC 156

I will therefore analyze the Appellant’s circumstances with the foregoing considerations in mind. ...
TCC

Abbass v. The King, 2023 TCC 169

However, after careful consideration, I conclude that the Accountant's testimony is credible. ...
TCC

Desgagnés Marine St-Laurent Inc. v. M.N.R., 2023 TCC 147

Other considerations are also present and clearly seen, but the possibility of these future qualified employees being recruited must not be disregarded. [56] In his testimony, Mr. ...
T Rev B decision

Wickett and Craig LTD v. Minister of National Revenue, [1978] CTC 2516, [1978] DTC 1382

Both parties also submitted for consideration the provisions of section 1801 of the Income Tax Regulations. ...
TCC

Taran Furs (Montreal) Inc. v. Minister of National Revenue, [1996] 1 CTC 2819

As mentioned in the Commentary of the United Nations Model Convention:...while interest on deferred-payment or credit sales should be considered in the context of the treaty article on interest, the nature of that consideration and the final resolution should be settled through negotiations between the parties. 63. ...
EC decision

Dominion Distillery Products Co. v. His Majesty the King, [1935-37] CTC 364, [1920-1940] DTC 369

The consideration for the sale was the issue by the purchasing corporation to the vendor, the suppliant company, of the sum of $1,200,000 payable in the fully paid preference stock and common shares of the purchasing corporation, and which stock and Shares were distributed among the shareholders of the suppliant company, four or five in number, I believe, and who alone thereafter held all the stock and shares of the Dominion Distillers Ltd. ...
EC decision

His Majesty the King, on the Information of the Attorney-General of Canada v. Dominion Engineering Company Limited,, [1943] CTC 5

After due consideration I have reached the conclusion that the contract in suit is governed by the first proviso of section 86, 1(a), that the progress payments therein stipulated fell due and were exigible in the proportion the work progressed and that the sales tax thereon was payable pro tanto at the time such payments fell due and became payable. ...
TCC

Fournier Giguère v. The King, 2022 TCC 132

Counsel for the appellant stated in writing that the game records from the Full Tilt Poker website were not available and that he and his client would not take steps to obtain the above‑mentioned records from the other gambling websites. [74] The appellant’s unreported business income was determined using the net‑worth method following an audit of the appellant’s personal bank records; his credit card statements; the Equifax report; the land register in relation to the residence that the appellant had acquired, which was located at 3637 Robert‑Lepage Street in Quebec City; the appellant’s file at the Société d’assurance automobile du Québec; various interviews given by the appellant; and other information about the appellant that was available on the Internet. [75] The appellant’s net worth was compiled following consideration of a document entitled “ Sommaire de l’actif et du passif à partir de février 2012 ” ([translation] “summary of assets and liabilities from February 2012”), which the appellant’s counsel submitted at the initial interview with the appellant. ...

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