Search - consideration

Counsel for Oriole submits that I should take these amounts into consideration in determining whether or not the $1,000,000 pay-out for the employment contracts represented a reasonable figure. ... When I consider this last bit of evidence it only confirms once again that the May 1,1976 amendments were not bona fide amendments to the contracts but only devices so that the portion of the consideration of the share purchase allocated to the employment contract pay-outs could be clothed with some credibility. ... As the payment of the $1,000,000 constituted partial consideration for the transfer by Flanagan and Burroughs to A.E.G. of their shares in Oriole it was not an expense incurred for gaining or producing income from a business within the meaning of paragraph 18(1)(a) of the Income Tax Act, R.S.C. 1952, c. 148 (am. ...

We cannot take your claim of mental distress into consideration in our review as you did not provide the requested documents. ... The Court looks to ensure that administrative decisions are made using a fair, open and appropriate procedure that provides an opportunity for those affected by the decision to understand the case they have to meet and put forward their views and evidence fully for consideration by an impartial decision maker (Canadian Pacific at para 41). ... The Applicant received such notice whether or not it was in the form of an education letter. [44] I find that the Applicant understood the case he had to meet and was given opportunities to provide both his position and evidence to support it for consideration by the CRA, but failed to do so (Canadian Pacific at para 41). ...

She explained: [Y]ou have to take into consideration that your file could not be worked by the Appeals section as they had to wait for the outcome of the related Kossow case. ... This Information Circular sets out a non-exhaustive list of factors for consideration by the MD, including: “(a) extraordinary circumstances, (b) actions of the CRA; (c) inability to pay or financial hardship” (Information Circular at para 23). ... However, you have to take into consideration that your file could not be worked by the Appeals section as they had to wait for the outcome of the related Kossow case. ...

Such special considerations would reflect on the very nature of trading activities in corporate securities. ... Campbell further observes at page 174: Without consideration of special interest purchaser considerations, fair market value or fair value becomes intrinsic value under the investment approach. ... Campbell, while recognizing the willingness of the courts to evaluate special purchaser considerations, suggests that courts may be reluctant to entertain such considerations when they are too speculative. 7. ...

Iao maintains that the Koo test makes no concession for this consideration in the spousal sponsorship context. ... Based on that finding, the IAD was precluded by section 65 of the IRPA from assessing H&C considerations. ... Immigration and Refugee Protection Act, SC 2001, c 27 Humanitarian and compassionate considerations 65.   ...

The assets, other than inventories, will be sold and transferred to Quatsino as at June 30th, 1960 for a total consideration of $116,212.75, comprising $90,000 for boats, fixtures, logging equipment, etc and $26,212.75 for land and timber. ... On the same date he sold the shares to a third party for a sum substantially in excess of the value attributed to them when he acquired them as part of the consideration for the sale of the hotel. ... While in the present case the assets were not sold to Quatsino for a consideration expressed partially in cash and partially in shares of that company, they were in effect sold to Rayonier for a consideration to be paid in part in cash by Quatsino with funds provided by Rayonier and in part by Rayonier undertaking to buy shares which appellant would subscribe in Quatsino, at a pre-arranged price, greatly in excess of what appellant had paid for them. ...

Subsequent to the payment of the aforesaid maintenance and in consideration of the said payments ana in consideration for the husband transferring to his wife his interest in the marital home, the wife waives all future rights to maintenance, support or alimony from the husband for herself. 9. ... Later cases were to examine other factors in order to determine if the payments were in substance alimony or a payment in consideration of the renunciation of marital rights. ... In such a case the alimony or allowance cannot be a total fixed amount payable by instalments up to the amount of $20,000 over a period of five years as in the case at bar, as the consideration for alimony or an allowance is the need of the creditor, whereas here the consideration is the waiver of benefits resulting from the marriage contract. ...

However, such performance should be regarded as having been achieved only when reasonable assurance exists regarding the measurement of the consideration that will be derived from rendering the service. ... (a) Consideration. When consideration is not determinable within reasonable limits, for example, when payment relating to goods sold depends on the resale of goods by the buyer, revenue would not be recognized. ... Sections 1000.39 and 3400.18(a) of the CICA Handbook provide that unless a reasonable estimate can be made or when consideration is not determinable within reasonable limits, revenues would not be recognized. ...

The only ground for consideration by an officer conducting a decision review is whether the employee was treated arbitrarily as defined in the CRA Staffing Recourse Program. ... Issues   [11]            The applicant submitted the following issues for consideration:             1.         ... But the Applicant raises two further points that require consideration.   109.     ...

This is a business use of funds choice and not a circumstance for consideration of waiver and interest.” ... She deposed that she did not take into consideration the fact that CPET had filed protection from its creditors under the CCAA in making her decision. ... White are completely devoid of any consideration of the factors set out in paragraph 10 of the Guidelines. ...