Search - consideration

The Minister reassessed the Appellant to apply subsection 80(1) of the Income Tax Act (the “Act”) to the difference between the amount of the assigned debts and the trading price of the shares issued by CL as consideration for the assignments. ...

When the trial resumed on April 5, 1994, I advised the parties that I am dismissing the second branch of the motion and that I am deferring consideration of the first part of the motion until hearing at least part of the evidence. ...

But this consideration gets, at best, only to a finding that farming is a "source of income", not that it is "a chief source of income", as required by subsection 31(1) of the Income Tax Act. ...

The language of the statute is somewhat inapt to these technical considerations but its purpose is clear: and it is incumbent on the Court to see that the substance of a dispute is regarded and not its form. ...

That document contemplates that the advice might well involve entry into an arrangement of the sort now under consideration. ...

I would point out the following: A. the subsidy arrangement was a benefit in that it added at least some inducement-a positive element-to his consideration of the bare alternative of loss of employment, and B. non-taxability of the amount in Mr. ...

As partial consideration for the sale of all its properties, Serin (U.S.) received interest-bearing promissory notes the values of which at the date of liquidation was reflected by their principal amounts as follows: The contents of this table are not yet imported to Tax Interpretations. 6. ...

In affirming his judgment in the Supreme Court of Canada, Cartwright, C.J. said at page 498 (C.T.C. 164, D.T.C. 5098): After a consideration of the arguments of counsel and the authorities to which they made reference I find myself so fully in agreement, not only with the conclusion of the learned Exchequer Court judge but also with his reasons, that I am content simply to adopt them. ...

Even permanency of abode is not essential since a person may be a resident though travelling continuously and in such a case the status may be acquired by a consideration of the connection by reason of birth, marriage or previous long association with one place. ...

Dickson, J. suggests the consideration of some criteria, although he cautions that his list of criteria is not exhaustive. ...