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FCTD

The Queen v. Jeromel, 86 DTC 6370, [1986] 2 CTC 207 (FCTD)

Since the hearing I have reviewed the collective agreement entered in evidence and have considered the cases submitted by counsel and have come to the conclusion that the defendant, during the period relevant to the consideration of this matter, was not employed by the Board and accordingly was not required to carry out any duties of employment. ...
FCA

Roywood Investments Ltd. v. The Queen, 81 DTC 5148, [1981] CTC 206 (FCA)

It cannot be said he overlooked any material evidence or took into consideration factors for which there was no evidence. ...
FCA

Perkins v. The Queen, 80 DTC 6154, [1980] CTC 199 (FCA)

In our view, all of the relevant findings of fact made by the learned trial judge were open to him on the evidence adduced; the conclusions and inferences which he drew from the proven facts were not erroneous and were drawn by him only after an extensive consideration and review of the evidence. ...
TCC

Edmondson v. MNR, 88 DTC 1542, [1988] 2 CTC 2185 (TCC)

As a consideration for doing this the appellant insisted on co-signing all cheques and having his daughter, an experienced bookkeeper, work for the Company. ...
SCC

Robson v. Minister of National Revenue, 52 DTC 1088, [1952] CTC 85, [1952] 2 SCR 223

The same construction results from a consideration of the French version of the text:— 1 ‘ et doit comprendre l’intérêt, les dividendes ou profits directement ou indirectement reçus de fonds placés à intérêt sur toutes valeurs ou sans garantie, ou d’actions, ou de tout autre placement, et, que ces gains ou profits soient partagés ou distri- bués ou non, et aussi les profits ou gains annuels dérivés de toute autre source, y compris. ’ ’ The distribution of the shares by Timberland was not a distribution of capital of that company. ...
FCTD

Finochio v. The Queen, 87 DTC 5228, [1987] 1 CTC 313 (FCTD)

Ross indicated they were concerned and contacted their insurers) and income tax considerations, all of which would benefit from seeing the letter. ...
FCA

Loman Warehousing Ltd. v. Canada, 2000 DTC 6610 (FCA), aff'g 99 DTC 1113, Docket: 98-201-IT-G (TCC) infra

Dreyfus (1906) 1 K.B. 584 at 589), but would also include one who lends money on a regular and continuous basis over time to a limited group of borrowers for an arm's length consideration (see in particular the extended meaning of the word "business" in par. 248(1)). ...
FCTD

Intertan Canada Ltd. v. MNR, 96 DTC 6522, [1996] 3 CTC 257 (FCTD)

It reads as follows: 5301(1) Subject to subsection (6) and (8), for the purposes of subsections 157(4) and 161(9) of the Act, the “first instalment base” of a corporation for a particular taxation year means the product obtained when the tax payable by the corporation under Part I of the Act, computed without reference to sections 123.3 to 123.5, 127.2 and 127.3 thereof and before taking into consideration any amount referred to in any of subparagraphs 161 (7)(a)(i) to (vii) thereof that was excluded or deducted, as the case may be, for its taxation year immediately preceding the particular year, is multiplied by the ration that 365 is of the number of days in that preceding year. ...
FCA

Vitellaro v. Canada (Customs and Revenue Agency), 2005 DTC 5275, 2005 FCA 166

Vitellaro, dated March 15, 2004, and the amount of the appellants' tax indebtedness to the CCRA are taken into consideration.                                                                                                                                    ...
TCC

Dufour v. MNR, 90 DTC 1238, [1990] 1 CTC 2351 (TCC)

The Tax Court of Canada judge had allowed the application, on the basis that the accountant's efforts to deal with the problem directly with the Department of National Revenue could be taken into consideration and that, accordingly, the application for an extension was filed as soon as the circumstances permitted. ...

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