Search - consideration
Results 4671 - 4680 of 11360 for consideration
FCTD
Irving Oil Ltd. v. The Queen, 88 DTC 6138, [1988] 1 CTC 263 (FCTD), aff'd 91 DTC 5106 (FCA)
This is a matter of dispute yet to be resolved, after consideration of the main issues. ... And the advent of VLCC tankers, was that a part of the consideration on your side in the price negotiations at the contract negotiations? ... This is a consideration quite apart from the notion of sham: Stubart, (pp. 566-67; C.T.C. 309-10). ...
SCC
National Corn Growers Assn. v. Canada (Import tribunal), [1990] 2 SCR 1324
First, it was not patently unreasonable for the Tribunal to give consideration to the terms of the GATT in interpreting s. 42 of SIMA . ... These criteria could reasonably be interpreted as encompassing, in a case such as this one, consideration of the strong potential for increased amounts of subsidized imports. ... These criteria could reasonably be interpreted as encompassing, in a case such as this one, consideration of the strong potential for increased amounts of subsidized imports. ...
FCTD
Makivik Corporation v. Canada (Environment and Climate Change), 2019 FC 1297
This is why we cannot accept restrictions that are driven by considerations of international trade. ... However, I am persuaded by the AG of Canada’s arguments that CITES or any consideration of a possible trade ban was properly considered in the Minister’s balancing. ... The Cree Respondent argues that the Minister failed to take the NMRWB’s findings into consideration and substituted them with its own. ...
FCTD
Sweet v. Canada, 2022 FC 1228
That question is whether there exist residual policy considerations which justify denying liability. Residual policy considerations include, among other things, the effect of recognizing that duty of care on other legal obligations, its impact on the legal system and, in a less precise but important consideration, the effect of imposing liability on society in general. ... (iv) Policy Considerations [106] I therefore turn to the second stage of the Anns/Cooper test. ...
TCC
Cassan v. The Queen, 2017 TCC 174
Johnson’s analysis of the interest rate in turn involves consideration of the following: a. ... The IRR is merely information to be taken into consideration. 2. The high end of Mr. ... It involves a transaction without a valid legal consideration. “In fact, if there be a consideration the transaction is no longer a gift, but a contract.” ...
TCC
Univar Canada Ltd. v. The Queen, 2005 DTC 1478, 2005 TCC 723
I’m asking you specifically: What Canadian tax considerations were there? ... A: No, Canadian tax considerations didn’t primarily motivate that. ... Additional strategies with probable high payoffs and other strategies on a continuing consideration… Mr. ...
FCTD
Anglehart v. Canada, 2016 FC 1159
One of its provisions was to limit the number of fishing licences based on biological and economic considerations. ... At this stage, the courts will have regard to the reasonable expectations of the parties and public policy considerations. ... In 2004, RPPIM obtained a quota of 400 mt in consideration of $1.5 million in financing; in 2005, AGFA obtained a quota of 480 mt in consideration of $1.9 million in financing, whereas in 2006, it obtained a quota of 1000 mt in consideration of $1.5 million in financing. ...
SCC
Schmidt v. Air Products Canada Ltd., [1994] 2 SCR 611
Different considerations apply if the fund is impressed with a trust. ... These general considerations are, of course, subject to applicable legislation. ... If, however, the fund is impressed with a trust, different considerations apply. ...
SCC
65302 British Columbia Ltd. v. Canada, 99 DTC 5799, [1999] 3 SCR 804
“The Deductibility of Fines: Considerations From Law and Policy Perspectives” (1984), 13 Austl. ... In light of these considerations, Lamarre J.T.C.C. concluded that the levy imposed by the Board under s. 6(e) of the Standing Order was not a penalty. ... These considerations all point to characterizing the levy as a current expense. ...
FCA
ExxonMobil Canada Ltd. v. Canada, 2010 FCA 1
[38] Paragraph 170(1)(b) provides that no ITCs may be claimed with respect to property or services acquired “exclusively for the personal consumption, use or enjoyment” of an employee (the benefit), unless the employee has paid adequate consideration or the benefit does not otherwise result in an income inclusion pursuant to section 6 of the ITA (i.e., it is not a taxable benefit). ... It is also impossible to determine whether the amount of the tax that an employer is deemed to have paid with respect to an allowance pursuant to section 174 is calculated on a consideration or value that is reasonable in the circumstances, as contemplated by paragraph 170(2)(b), given that such “consideration” or “value”, if any, is unknown ... Restriction 170. (1) In determining an input tax credit of a registrant, no amount shall be included in respect of the tax payable by the registrant in respect of … (b) a supply, importation or bringing into a participating province of property or a service that is acquired, imported or brought in by the registrant at any time in or before a reporting period of the registrant exclusively for the personal consumption, use or enjoyment (in this paragraph referred to as the “benefit”) in that period of a particular individual who was, is or agrees to become an officer or employee of the registrant, or of another individual related to the particular individual, except where (i) the registrant makes a taxable supply of the property or service to the particular individual or the other individual for consideration that becomes due in that period and that is equal to the fair market value of the property or service at the time the consideration becomes due, or (ii) if no amount were payable by the particular individual for the benefit, no amount would be included under section 6 of the Income Tax Act in respect of the benefit in computing the income of the particular individual for the purposes of that Act; and (c) a supply made in or before a reporting period of the registrant of property, by way of lease, licence or similar arrangement, primarily for the personal consumption, use or enjoyment in that period of (i) where the registrant is an individual, the registrant or another individual related to the registrant, (ii) where the registrant is a partnership, an individual who is a member of the partnership or another individual who is an employee, officer or shareholder of, or related to, a member of the partnership, (iii) where the registrant is a corporation, an individual who is a shareholder of the corporation or another individual related to the shareholder, and (iv) where the registrant is a trust, an individual who is a beneficiary of the trust or another individual related to the beneficiary, except where the registrant makes a taxable supply of the property in that period to such an individual for consideration that becomes due in that period and that is equal to the fair market value of the supply at the time the consideration becomes due. ...