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Legislation [18]         For the purposes of the CCTB section 122.6 of the Income Tax Act defines the following terms “eligible individual” in respect of a qualified dependant at any time means a person who at that time (a) resides with the qualified dependant, (b) is a parent of the qualified dependant who (i) is the parent who primarily fulfils the responsibility for the care and upbringing of the qualified dependant and who is not a shared-custody parent in respect of the qualified dependant, or (ii) is a shared-custody parent in respect of the qualified dependant, and, for the purposes of this definition, (f) where a qualified dependant resides with the dependant's female parent, the parent who primarily fulfils the responsibility for the care and upbringing of the qualified dependant is presumed to be the female parent, (g) the presumption referred to in paragraph 122.6 eligible individual (f) does not apply in prescribed circumstances, and (h) prescribed factors shall be considered in determining what constitutes care and upbringing; “qualified dependant” at any time means a person who at that time (a) has not attained the age of 18 years, (b) is not a person in respect of whom an amount was deducted under paragraph (a) of the description of B in subsection 118(1) in computing the tax payable under this Part by the person’s spouse or common-law partner for the base taxation year in relation to the month that includes that time, and (c) is not a person in respect of whom a special allowance under the Children’s Special Allowances Act is payable for the month that includes that time; “shared-custody parent” in respect of a qualified dependent [sic] at a particular time means, where the presumption referred to in paragraph (f) of the definition “eligible individual ” does not apply in respect of the qualified dependant, an individual who is one of the two parents of the qualified dependant who (a) are not at that time cohabitating spouses or common-law partners of each other, (b) reside with the qualified dependant on an equal or near equal basis, and (c) primarily fulfil the responsibility for the care and upbringing of the qualified dependant when residing with the qualified dependant, as determined in consideration of prescribed factors, [19]         The prescribed factors to consider in determining whether one parent primarily fulfills the care and upbringing of the Children are listed in section 6302 of the Income Tax Regulations (the “Regulations”) as follows: 6302 For the purposes of paragraph (h) of the definition “eligible individual” in section 122.6 of the Act, the following factors are to be considered in determining what constitutes care and upbringing of a qualified dependant: (a) the supervision of the daily activities and needs of the qualified dependant; (b) the maintenance of a secure environment in which the qualified dependant resides; (c) the arrangement of, and transportation to, medical care at regular intervals and as required for the qualified dependant; (d) the arrangement of, participation in, and transportation to, educational, recreational, athletic or similar activities in respect of the qualified dependant; (e) the attendance to the needs of the qualified dependant when the qualified dependant is ill or otherwise in need of the attendance of another person; (f) the attendance to the hygienic needs of the qualified dependant on a regular basis; (g) the provision, generally, of guidance and companionship to the qualified dependant; and (h) the existence of a court order in respect of the qualified dependant that is valid in the jurisdiction in which the qualified dependant resides. ... Their parenting styles may have been different but that is not a consideration in deciding who is entitled to the benefits in issue: Hrushka v R, 2013 TCC 335 at paragraph 26. ...

  (1) Subject to this Part, every recipient of a taxable supply made in Canada shall pay to Her Majesty in right of Canada tax in respect of the supply calculated at the rate of 5% on the value of the consideration for the supply. ...   (2) Where, in the course of an activity that involves the organization, promotion hosting or other staging of a competitive event, a person gives a prize to a competitor in the event,   (a) the giving of the prize shall be deemed, for the purposes of this Part, not to be a supply;   (b) the prize shall be deemed, for the purposes of this Part, not to be consideration for a supply by the competitor to the person; and   (c) tax payable by the person in respect of any property given as the prize shall not be included in determining any input tax credit of the person for any reporting period. ...

If these conditions were fulfilled, the appellant asked that Affordable be reorganized to include the appellant’s participation as a shareholder and director of Affordable. [6] In consideration of the appellant’s guarantee and management assistance, the appellant’s corporation, Femco Financial Corporation Ltd. ... Rather, the Act contains both objective elements embodied in the reasonable person language and subjective elements inherent in individual considerations like “skill” and the idea of “comparable circumstances”. ...

The balance of $834 would be the amount, before income tax considerations are applied, which the mother should contribute to the father's child care expenses. ... In such a situation, I can see no other reasonable interpretation than to assume that the British Columbia Supreme Court intended the fourth order to have been made nunc pro tunc. [13] In the present case, the tax considerations taken into account by the Divisional Court in increasing the child support payments to be made by the Appellant effective December 1, 1992, are certainly an indicator of retroactivity and, as in the Larsson case, may defeat the presumption against retroactivity. ...

In addition to the powers conferred on her by law, my testamentary executor shall be entitled: (a) to sell, exchange or otherwise alienate all of the movable and immovable property included in my estate on the terms and for a price in money or any other consideration she considers appropriate, and to receive such price or consideration and give a receipt therefor; (b) to borrow any sum of money and, for that purpose, to pledge or hypothecate my movable or immovable property, as appropriate; (c) to agree to a transaction, compromise or settlement, or to arbitration, in respect of any claim by or against my estate, inter alia by giving or receiving any immovable in payment of any debt owed by or to my estate, and to grant discharges or releases; (d) to make any investments she considers appropriate, without being subject to articles 981o et seq. of the Civil Code; (e) to effect any partition of my property herself and, for this purpose, to appraise the property, form shares thereof and allocate them to the persons concerned using whatever methods she considers appropriate, without any authorization or judicial formalities, even if one of my legatees is a minor, an incapable person or an absentee, in which case such legatee shall be represented by my testamentary executor; (f) to permanently decide any question that may arise during her administration, realization of property, liquidation, partition, etc., her decisions to be final and binding on all of my legatees, with no possible appeal; (g) to draw from the capital of my estate any sum of money of which any of my legatees may be in urgent need and, inter alia, to use any sum of money required for the upbringing, education, board or clothing of my minor legatees, if any. [4] To fulfil her mandate as testamentary executor, Germaine Aubé retained Paul-Henri Gamache, an accountant, who was the only witness heard in support of the appeal. [5] Referring to a report made up of 50 documents, Mr. ...

The main charging provision of the GST legislation is subsection 165(1) which states: 165(1) Subject to this Part, every recipient of a taxable supply made in Canada shall pay to Her Majesty in right of Canada tax in respect of the supply calculated at the rate of 7% on the value of the consideration for the supply. ... These factors should then be analyzed to determine what weight they should be given in identifying the location of the property, in light of three considerations: (1) the purpose of the exemption under the Indian Act; (2) the type of property in question; and (3) the nature of the taxation of that property. ...

No exhaustive list has been compiled and perhaps no exhaustive list can be compiled of considerations which are relevant in determining that question, nor can strict rules be laid down as to the relative weight which the various considerations should carry in particular cases. ...

No exhaustive list has been compiled and perhaps no exhaustive list can be compiled of considerations which are relevant in determining that question, nor can strict rules be laid down as to the relative weight which the various considerations should carry in particular cases. ...

I was quite surprised that you did not take child care expenses into consideration in my 1994 and 1995 tax returns. ... Thanking you for your consideration, J.L. Charbonneau, M.D. 41 200 94/06/23 [8] As Exhibit A-3, a report by Dr. ...

Exhibit R-5 is headed “Full and Final Release” and states in part: IN CONSIDERATION of the payment of the sum of NINETEEN THOUSAND SIXTY THREE DOLLARS AND TWENTY EIGHT CENTS ($19,063.28) inclusive of costs which is directed to my solicitors, Cockburn, Foster, Townsend, Graham & Associates, In Trust. ... AND IT IS HEREBY DECLARED that the terms of this settlement are fully understood, that the amount stated herein is the sole consideration for this release and that the said sum is accepted voluntarily for the purpose of making a full and final compromise, adjustment and settlement of all claims for injuries, losses and damages resulting or to result from the said accident. [8] The final document signed by the Appellant is entitled a “Release, Direction and Authorization” (Exhibit R-6). ...