Search - consideration
Results 241 - 250 of 11351 for consideration
TCC
Jayco, Inc. v. The Queen, 2018 TCC 239
On the contrary, I think the enumerated considerations in clauses (a) to (h) provide guidance as to matters that might be considered relevant in clause (i). 25. ... Taking risk into consideration would result in an increase in the costs awarded only against the defendant. 27. ...
TCC
CAE Inc. v. The Queen, 2011 DTC 1362 [at at 2031], 2011 TCC 354, aff'd 2013 DTC 5084 [at 5944], 2013 FCA 92
Analysis [46] General considerations [47] Nature of the business [67] It is important to bear in mind the nature of the appellant's business in the field of civil aviation ... " (Emphasis added.) is also a relevant consideration. [70] This would be the result regardless of the test. [71] Two simulators for Air Canada and two for the Toronto training centre. [72] In Minister of National Revenue v. ... In the result, the respondent obtained, by its exchange of trading lands, land which it was able to sell for a cash consideration of $1,000,000, being the value placed on the land by the purchaser. ...
TCC
Banque Laurentienne du Canada v. The Queen, 2020 TCC 73
He was therefore the only witness able to enlighten the Court on the intention of the parties in relation to the services rendered by CDPQ as consideration for the payment of transaction fees. ... Minister of National Revenue [83]: It is not a question of the Minister or his Court substituting its judgment for what is a reasonable amount to pay, but rather a case of the Minister or the Court coming to the conclusion that no reasonable business man would have contracted to pay such an amount having only the business consideration of the appellant in mind. ... Rather, counsel for the respondent argued that the fees were unreasonable because Laurentian Bank did not receive any consideration for them [90]. [90] The amount of this expense was not questioned by counsel for the respondent, but he nevertheless considered it completely unreasonable. ...
FCA
Canada v. Benoit, 2003 DTC 5366, 2003 FCA 236
The seriousness of an allegation made, the inherent unlikelihood of an occurrence of a given description, or the gravity of the consequences flowing from a particular finding are considerations which must affect the answer to the question whether the issue has been proved to the reasonable satisfaction of the tribunal. ... In my view, the Trial Judge erred in not taking this evidence into consideration. ... She stated that this inquiry was appropriate in respect of both the admissibility and the weight to be given to the witness' evidence, if admitted. [103] I agree entirely with the appellants that the Trial Judge could not defer his consideration of this issue to "the community. ...
FCTD
Heckendorn v. Canada, 2005 DTC 5310, 2005 FC 802
CONSIDERATION Claim Against the Individual Defendants [3] There is no allegation against the individual Defendants, who are employees or former employees of Canada Customs and Revenue Agency ("CCRA"), and who were involved in the collection process, that they were on a frolic of their own or acted outside of the scope of their employment. ...
TCC
Picard v. The Queen, 2008 TCC 506
These factors should then be analyzed to determine what weight they should be given in identifying the location of the property, in light of three considerations: (1) the purpose of the exemption under the Indian Act; (2) the type of property in question; and (3) the nature of the taxation of that property. ...
FCTD
Seaspan International Ltd. v. Ewa (Ship), 2004 FC 124
CONSIDERATION Scope of Production of Documents [6] The Defendants, who in the questions objected to are essentially looking for documents, begin with a general proposition from Everest & Jennings Canada Ltd. v. ...
TCC
Fortnum v. The Queen, 2018 TCC 126 (Informal Procedure)
A consideration of the amendment itself and its purpose leads me to conclude that the word "course" refers to a single course within a curriculum of studies as was determined by Paris J. in Ferre and not the entire curriculum as was determined by Bowie J. in Siddell. ...
FCTD
Canada (National Revenue) v. Montana, 2019 FC 900
The course of an audit is directed by a multitude of factors, including the auditors’ experience, training, the state of the records, the tax history of the taxpayer as well as considerations external to the particular taxpayer. ...
FCTD
Canada (National Revenue) v. CN Construction Networks Ltd., 2020 FC 775
The course of an audit is directed by a multitude of factors, including the auditors’ experience, training, the state of the records, the tax history of the taxpayer as well as considerations external to the particular taxpayer. ...