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Results 4301 - 4310 of 11351 for consideration
TCC

Brad-Lea Meadows Ltd. v. MNR, 90 DTC 1269, [1990] 1 CTC 2306 (TCC)

The consideration of the affiliation fee is the sole issue in this appeal. ...
FCTD

Re Stern, 85 DTC 5002, [1984] CTC 647 (FCTD)

Thus, the question is large, and the consideration of adaptation of the rules is not out of the question. ...
FCTD

Usarco Ltd. v. A.G. Canada, [1980] CTC 484, 80 DTC 6381 (FCTD)

In our opinion, the principal consideration which should govern the exercise of the discretion under Rule 401 is whether the defendant has prima facie raised sufficient doubt as to the regularity of the proceedings or the jurisdiction ratione personae of the Court that justice requires he be permitted to appear in such a manner as to avoid any waiver of his objections. ...
TCC

Bertram v. The Queen, 93 DTC 1251, [1993] 2 CTC 2982 (TCC)

McRae, for no other consideration, his option to purchase 44,500 shares from Edgewater for 16¢ per share. ...
TCC

Hewitt v. MNR, 89 DTC 451, [1989] 2 CTC 2278 (TCC)

If the single cash payment out of the Plan had been long delayed, or the amount payable had been spread out over a period of time in a series of payments, other considerations would arise as to (i) whether a portion of the amount received accrued or was earned while the appellant was resident in Canada; or (ii) whether the payments were a "superannuation or pension benefit" within the meaning of the Income Tax Act. ...
TCC

Sommers v. The Queen, 93 DTC 1489, [1993] 2 CTC 3122 (TCC)

I do not believe Sommers’ success in having the charges dismissed is a relevant consideration herein. ...
TCC

Horkoff v. The Queen, 97 DTC 621, [1996] 3 CTC 2737 (TCC)

(the “Purchaser”) hereby offers to purchase all of the issued and outstanding shares in the capital stock of the Company from Ed Horkoff and Marion Horkoff (collectively referred to as the “Vendors”) for the consideration and on the terms and conditions following: 1. ...
TCC

Tinianov v. M.N.R., docket 97-1126-UI

Taking into consideration all of the circumstances of this appeal, including the testimony of the witnesses, the admissions and the documentary evidence in the light of the case law provided to me by counsel, I am satisfied that the Appellant has failed in this onus; in my opinion, only the fact that the parties were not dealing at arm's length reasonably explains the Appellant's working conditions and remuneration during the period in issue. [12] The employment of the Appellant during the period in issue is excepted from insurable employment pursuant to paragraph 3(2)(c) of the Unemployment Insurance Act and subsection 5(2) of the Employment Insurance Act. [13] The appeal is accordingly dismissed and the Minister's decision dated March 25, 1997 is confirmed. ...
TCC

Popovich v. The Queen, docket 97-2412-IT-I (Informal Procedure)

(f) on May 27, 1987, the Appellant and his spouse borrowed $125,000.00 from the Canadian Imperial Bank of Commerce by way of a first mortgage secured by their principal residence; (g) on September 17, 1987, the Corporation borrowed $150,000.00 from a company, bearing interest at 14% per annum, by way of a second mortgage secured by the Property; (h) on April 7, 1989, the Appellant and his spouse obtained by way of a second mortgage loan on their principal residence from Canadian Imperial Bank of Commerce the sum of $125,000.00 with interest at the rate of 15.25% per annum; (i) on April 14, 1989, the Appellant and a partner purchased an assignment of the second mortgage on the Property for a consideration of $160,938.49; (j) on April 16, 1991, the Property was sold to Canada Fine Art & Frame for $325,000.00;... ...
TCC

Kaye v. The Queen, docket 97-2772-IT-I (Informal Procedure)

He or she would also consider whether the person claiming to be in business has gone about it in an orderly, businesslike way and in the way that a business person would normally be expected to do. [6] This leads to a further consideration — that of reasonableness. ...

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