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FCTD

Fonthill Lumber Ltd. v. The Queen, 81 DTC 5333, [1981] CTC 406 (FCTD)

In the Sylvania decision Cattanach, J concluded that special tax consideration in which no funds passed to the taxpayer would be an unwarranted extension of the genus of grant or subsidy. ...
FCA

Nova Construction Sand and Gravel Ltd. v. The Queen, 80 DTC 6298, [1980] CTC 378 (FCA)

This led to a broad meaning being given to the words “manufactured” and “produced” in their context in the Excise Tax Act provision under consideration. ...
TCC

Stevenson v. The Queen, 2001 DTC 1019 (TCC)

Both the appellants, father and son, testified that it was one of the considerations that motivated their buying the combine when they did. ...
FCTD

Suzy Creamcheese (Canada) Ltd. v. The Queen, 92 DTC 6291, [1992] 1 CTC 242 (FCTD)

It is a material consideration, however, that such a sum was earmarked for capital purposes, i.e., the installation of the necessary fixtures in an otherwise barren space. ...
FCTD

Macmillan Bloedel (Alberni) Ltd. v. MNR, 73 DTC 5264, [1973] CTC 295 (FCTD)

.* [2] Those two cases are quite different on their facts and on the sections of the Income Tax Act under consideration. ...
FCA

Jentel Manufacturing Ltd. v. Canada, 2012 DTC 5031 [at at 6682], 2011 FCA 355

The judge applied the correct legal test and his conclusions were based upon a thorough consideration of the evidence. ...
FCTD

Ondrey v. R., 98 DTC 6023, [1998] 1 CTC 317 (FCTD)

In the result I can not take either possible adjustment into consideration. ...
TCC

Eliyin v. The Queen, 2014 DTC 1120 [at at 3294], 2014 TCC 125

In the instrument of transfer, he acknowledged that the Freehold Estate transferred to Erfan was fee simple. [11]         As a result, I have given no consideration to the “Trust Agreement” in my final decision in this appeal. ...
TCC

Paajanen v. The Queen, 2011 DTC 1229 [at at 1333], 2011 TCC 310 (Informal Procedure)

Audet to share income unequally was not at all motivated by tax considerations. ...
FCTD

Babin v. Canada (Customs and Revenue Agency), 2005 DTC 5414, 2005 FC 972

The reviewing court should consider whether the discretion was "exercised in good faith and, where required, in accordance with the principles of natural justice, and where reliance has not been placed upon considerations irrelevant or extraneous to the statutory purpose" (see [1982] 2 S.C.R. 2 "> Re Maple Lodge Farms Ltd. ...

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