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Results 161 - 170 of 2335 for consideration
FCTD

Leonard v. Canada, docket T-651-87

(c)      as consideration or partial consideration for accepting the office or entering into the contract of employment,                            (d)      as remuneration or partial remuneration for services as an officer or under the contract of employment, or                            (e)      in consideration or partial consideration for a covenant with reference to what the officer or employee is, or is not, to do before or after the termination of employment.                   ...
FCTD

Tobias v. Canada (Citizenship and Immigration), 2019 FC 1167

It also found that the Applicant’s Former Partner was not a member of the Mara 18 gang, based largely on its consideration of evidence surrounding the Former Partner’s tattoos. ... The RPD’s analysis omits any consideration of this aspect of the Applicant’s explanation. [15]   The Applicants rely on Sadeghi v Canada (Citizenship and Immigration), 2011 FC 1236 [Sadeghi], which found that it was unreasonable for the RPD to rely upon inconsistencies between a refugee claimant’s evidence and an immigration form completed by an interviewing officer upon the claimant’s arrival in Canada. ... However, in my view, it was clearly necessary for the RPD to give consideration to the Applicant’s explanation, that the notes were not read or interpreted back to her, in considering whether the notes represented a reliable basis to impugn her credibility. ...
FCTD

Her Majesty the Queen v. Transcontinental Timber Company Limited, [1979] CTC 203, 79 DTC 5147

The group paid the company the sum of $95,000 in consideration thereof. ... The title to the bush road was taken over by the Crown so it formed no part of such consideration. ... The deposits of $45,000 were applied as part payment of the $95,000 consideration. ...
FCTD

Steen v. The Queen, 86 DTC 6498, [1986] 2 CTC 394 (FCTD), aff'd 88 DTC 6171, [1988] 1 CTC 256 (FCA)

On February 23, 1973 and again for a consideration of $1 the plaintiff was granted an option to purchase 600 additional common shares at a price of $33 per share. ... I therefore think that the market price, in a case like that under consideration, where it is shown to have been consistent, determines the fair market value of the shares. ... Paragraph 41 (2)(a) of the Companies Act (B.C.) reads as follows: 41. (2) No shares without par value shall be allotted or issued at a price or for a consideration less than, (a) where the memorandum or articles authorize the directors to determine the price or consideration, the price or consideration determined by them; 2 TParagraph 1 of IT-113 reads as follows: 1. ...
FCTD

The Queen v. Browning Harvey Ltd., 90 DTC 6105, [1990] 1 CTC 161 (FCTD)

NOW THEREFORE THIS AGREEMENT WITNESSETH that in consideration of the mutual convenants herein contained, and upon the terms and conditions hereinafter set forth, the parties hereto agree as follows: 1. ... In this respect counsel for the plaintiff has directed me to the capital cost allowance schedules of the defendant in its tax returns filed for each of the years under consideration. ... The covenants given by the shopkeepers in this case are a part of the consideration for the acquisition of the coolers. ...
FCTD

Gerus v. Canada (Canada Revenue Agency), 2009 FC 55

The issues in that case have no bearing on the issues in the case presently before me save to illustrate that the Program, including the recourse provisions, are in need of serious reform, especially with legal considerations in mind.     ... Those notes indicate that the Agency did move a person from CS-02 to CS-03 but a compromise was made to meet budget considerations.  ...   [19]            Section 2.2 of Annex S speaks of consideration to be given to those with Preferred Status “prior to initiating staffing with or without selection process” where as Section 2.3 speaks of consideration to be given to persons with Preferred Status “when they conduct a selection process”.  ...
FCTD

Pomeroy’s Masonry Limited v. Canada (Attorney General), 2017 FC 952

However, for purposes of identifying the applicable standard of review, it is sufficient to note that the decision turned on consideration of the circumstances surrounding the timeliness of the Applicant’s tax filings. ... I am not prepared to conclude, as advocated by the Applicant, that these were not relevant considerations; however, they are certainly not the only considerations that should have been taken into account. [27]            The Applicant’s written submissions in support of its re-appropriation requests explained that the Applicant is a small business employing five individuals and that, if CRA did not agree to allow the re-appropriation of the statute-barred credits to the company’s HST liability, Mr. ... Rather, it results from the fact that the record demonstrates no consideration or weighing at all of the Applicant’s submissions as to the effect upon it, and its ability to pay its HST liability, that would result from its request being refused. [29]            The failure to consider these factors may be attributable to the Guidelines’ emphasis on consideration of whether there were extraordinary circumstances which prevented the filing of returns within three years from the applicable tax year end. ...
FCTD

Budhram v. Canada (Citizenship and Immigration), 2019 FC 1185

Issues and Standard of Review [6]   The Applicant raises the following two issues for the Court’s consideration: Was the IAD’s Decision unreasonable because it took irrelevant considerations into account and failed to take relevant considerations into account? ... Was the IAD’s Decision unreasonable because it took irrelevant considerations into account and failed to take relevant considerations into account? [8]   The Applicant frames this issue as the IAD relying on irrelevant considerations and failing to take into account relevant considerations. ...
FCTD

Sioco v. Canada (Citizenship and Immigration), 2019 FC 1286

The Officer found the H&C considerations insufficient to warrant an exemption from subsection 117(1)(h) of the IRPR. ... [21]   The Applicant submits that the Officer made perverse findings based on the evidence, turning all of the evidence of a de facto family membership into negative H&C considerations.   ... Macata Castillo, the Officer would conclude that the Applicant’s needs are perfectly met in the Philippines, and if the Applicant does not provide such evidence, the Officer would dismiss H&C considerations for lack of evidence.   ...
FCTD

Anderton v. Canada (Attorney General), 2021 FC 788

According to memoranda dated February 19, 2020, prepared as part of CRA’s consideration of the remission requests [the Memoranda], CRA’s assessments of the Applicants’ income tax returns resulted in tax, late filing penalties and interest, totalling $14,044 and $1,680 owing by Mr. ... While Germain pre-dates Vavilov, I consider its conclusion to remain good law and agree with the parties that the reasonableness standard of review applies to my consideration of the Decisions. [26] The Respondent also raises a preliminary issue for the Court’s consideration. ... I agree with the Respondent that the concept of "public interest" cannot be viewed merely in terms of the interests of any one group of taxpayers, but rather must also take into consideration the concerns of society generally. ...

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