Search - consideration
Results 441 - 450 of 2336 for consideration
FCTD
Her Majesty the Queen as Represented by the Minister of National Revenue v. Ruth Beverly Bourassa, [1984] CTC 331
She is the owner of the mobile home under a bill of sale dated July 8, 1981, drawn in her favour by her husband for consideration of $1.00. ...
FCTD
Delvee Re-Education Inc. v. Minister of National Revenue, [1998] 4 CTC 18, [1998] 4 C.T.C. 19
</p>] which, pursuant to Section 18.29(1)(b), applies to appeals arising under Part III of the Unemployment Insurance Act, provides the following: 18.15 [...] (4) Notwithstanding the provisions of the Act out of which an appeal arises, the Court, in hearing an appeal referred to in section 18, is not bound by any legal or technical rules of evidence in conducting a hearing for the purposes of that Act, and all appeals referred to in section 18 shall be dealt with by the Court as informally and expeditiously as the circumstances and considerations of fairness permit. 4 In the case at bar, the applicant chose to be represented not by counsel, but by its president, Ms Morgan. ...
FCTD
Minister of National Revenue v. Gordon W Pannell, [1973] CTC 81, 73 DTC 5038
After a careful consideration of the whole of the evidence, and of the submissions of counsel, I am of the view that, notwithstanding the said charade in respect to certain of the letters of request and reply for consulting services, this is not a case where the evidence establishes that the Court should make any findings of fact for income tax purposes different or contrary to the expressed intention of the parties in the said contracts, and as carried out. ...
FCTD
Canada (National Revenue) v. Thornton, 2013 DTC 5008 [at 5541], 2012 FC 1313
Memo to File, March 22, 2006, Re: T3 and Other Tax Considerations, 3 pages by Craig Bell, CA LLP; c. ... In several places, it is difficult to ascertain whether the statements made are based on accounting or legal considerations. ... I am sympathetic to this position, and have therefore given some negative weight to these considerations. ...
FCTD
Bowater Power Co. Ltd. v. MNR, 71 DTC 5469, [1971] CTC 818 (FCTD)
Subsequently, appellant and respondent agreed that.the capital cost of both rights was $1,046,654.79 of which appellant says $104,665.47 may reasonably be regarded as consideration for the Corner Brook rights and the balance, or $941,989.32, may reasonably be regarded as consideration for the. ... The consideration for the grant was a small amount of $20 but comprised also the obligation to do some construction work and supply electricity. ... One consideration may point so clearly that it dominates othe rand vaguer indications in the contrary direction. ...
FCTD
Jones Estate v. Canada (Attorney General), 2009 FC 646
Since the 2003 return was filed on May 3, 2006, the late-filing penalty remains at 17% even though the Minister took into consideration a six-months mourning period. ... Even though the Minister took into consideration a mourning period from August 2004 to February 2005, the late filing penalty remained at the maximum of 17% of unpaid tax. ... In sum, the Minister did not err by relying on irrelevant considerations in making his decision. ...
FCTD
74712 Alberta Ltd. (Formerly Cal-Gas & Equipment Ltd. v. Her Majesty the Queen), [1994] 2 CTC 191, 94 DTC 6392
It is a time which the plaintiff, or its counsel, keeps amputating or ignoring from consideration in this narrative of events. ... In law consideration may be a promise for a promise, but the Court finds that, not in the textbook legal sense, but in the commercial, fiscal sense, the by now sturdy Cal-Gas ave that guaranty without adequate consideration. ... Here, the Court has already found that the consideration, if any, for Cal-Gas’ giving its guaranty of Anderson's and Trennd (1979)'s indebtedness, inter alia, was surely inadequate and so, IT-445 does not need any further consideration by the Court, herein. ...
FCTD
Rahman v. Canada (Attorney General), 2022 FC 806
Each is separate and a remission request is subject to its own review and considerations. ... There is no consideration of the fact that this outcome is the result of a statutory limitation in the power granted to the CRA. ... In my view this was a reasonably consideration and finding. [70] And again the Applicant chose not to file supporting documentation, not even a simple statement of her income and expenses, or a statement of her assets and liabilities. ...
FCTD
Grandjamb v. Canada (Parks), 2019 FC 1023
In my view, as seen from the above, the Superintendent’s mandate is broad and is not restricted only to a consideration of s 50(4) of the WBNP Game Regulations. ... The Record of Decision indicates that, based on the above Parks Canada then conducted its analysis, setting out the key factors for consideration. ... The obligation to consult was a discrete consideration, although it could, and did, give rise to concerns with the proposed location of the trapping cabin. ...
FCTD
First Fund Genesis Corp. v. The Queen, 91 DTC 5361, [1991] 2 CTC 14 (FCTD)
("Dell") issued debentures to the plaintiff for a total consideration of $7,500,000. ... That debenture was issued to the plaintiff in consideration for a purchase price of $3,871,600. ... Grinling (21) where, after holding that, in the context there under consideration, the meaning of the word was equivalent to “considerable, solid or big", he said: “Applying the word in this sense, it must be left to the discretion of the judge of fact to decide as best he can according to the circumstances of each case.... ...