Search - consideration

First of all, that this was a forgiveness of a debt, but it was not a consideration for the disposition of capital property to a person with whom the taxpayer was dealing at arm’s length, within the meaning of Section (40)(2)(g)(ii), and therefore was not a capital loss. ...

Analysis The Appellant is a lawyer who has made a profit from his practice during the years under consideration. ...

Taking into consideration all of the circumstances, including the testimony of the Appellant, the admissions, documentary evidence and submissions of the parties in the light of the criteria set out in the case law provided by the Appellant and counsel for the Minister, I am satisfied that the Appellant has not succeeded in establishing on a balance of probabilities that he had a reasonable expectation of profit from the rental of the property during the three taxation years in issue. ...

Evidently, it was in consideration of the moneys that she had spent and the services that she had performed over the years. ...

The allocation of the money paid by CARRA may not be taken into consideration in characterizing the lump-sum retroactive payment; how it is characterized is essentially a function of the source of the income. ...

The insurance premiums (and other consideration as well) had been paid to MICC to ensure total repayment of the loan principal in the event of default. ...

.: The Applicant seeks judicial review of a decision of an Immigration Officer (the “Officer”) dated January 27, 1998, wherein the Officer decided there were insufficient humanitarian and compassionate (“H & C”) considerations to recommend a favourable decision under Section 114(2) of the Immigration Act, R.S.C. 1985, c. ...

The facts that the Minister of National Revenue (the “Minister”) took under consideration to make the reassessments are described at paragraphs 2 and 4 of the Reply to the Notice of Appeal as follows: 2. ...

.): 12 Any doubt as to whether the taxpayer’s chief source of income is farming is resolved once consideration is given to the element of profitability. ...

Taking into consideration all of the circumstances of this appeal, including the testimony of the Appellant, the admissions and the documentary evidence in the light of the case law, I am satisfied that the Appellant has failed in this onus. ...