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Ward, “Tax Considerations Relating to the Purchase of Assets of a Business,” in Corporate Acquisitions, Reorganizations and Liquidations, 1972 Corporate Management Tax Conference 22–50. [39] MacMillan Bloedel, paragraph 8 (CTC). [40] Sullivan, pages 40 and 41. [41] Canada Trustco, paragraph 12. [42] Sullivan, page 326. [43] The Bank of Montreal v. ...

Furthermore, one has to keep in mind that the Minister has the responsibility to set out the case they are making against a taxpayer by fully setting out the assumptions of fact made by the Minister in making the assessment. [157] In this appeal, the Minister alleges a complicated tax scheme put in place by the Appellant for the benefit of numerous clients to allow them to sell assets without paying tax on the proceeds of disposition, in consideration for a fee, which was not reported by the Appellant as income. ...

Summary of the Proceedings [12] The facts summarized below were taken into consideration by the Court for issuing this Order. 2016 [13] On January 5, 2016, the Respondent filed a motion to quash John Doe’s appeal with respect to the 2009, 2010 and 2011 taxation years on the basis that John Doe had not met the requirements in order to file a valid appeal. [8] The hearing of the motion was scheduled for January 29, 2016, in Vancouver. [14] On January 22, 2016, the Court was made aware of the nature of John Doe’s hospitalization. ...

Dirk in his testimony, it appears that the reason for the change of employer was driven by foreign exchange control considerations. ...

Similar considerations apply for 2014 where only $5,000 in income was declared. ...

And then just getting back to-- and any documents that they provided, were they taken into consideration? ... That information would have been taken into consideration in doing the ruling. ... SO, what you're saying by that is there's a lot of people who were given consideration based on their own independent facts that aren't here today--- A.          ...

Morand, are another consideration tied to unreported sales. Furthermore, the evidence reveals that some employees' wages were paid out of income that was not on the books, and points to other expenses paid for in cash (Exhibits I‑11 and I‑12) ...

This is an important consideration on both questions as to whether or not he was capable of understanding that he was a director and on the due diligence test. [156]    Counsel admitted that the Appellant looked at some construction drawings, ordered materials and called the union. ...

A consideration of how their roles evolved over time will assist this Court in understanding the current roles that they now exercise within the Orthodox Jewish community. [102]      The balance of the Eleff Report is relevant to the issue before the Court. c)      Necessity in Assisting the Trier of Fact [103]      The Appellants submit that the Eleff Report does not meet the Mohan criteria because the report attempts to usurp the role of the trier of fact in its deliberate use of the word “congregation” throughout the report and uses it as a synonym for the word “synagogue”. ...

In consideration of the contracts established subsequent to applications or requests submitted by the Agent, the Company pays to his/her fund all remuneration related to these contracts as established according to the Company’s Commissions and Bonuses Schedules and Remuneration Rules, adjusted from time to time, which form an integral part of this contract. ... Lorsque vous en commanderez, veuillez prendre en considération que nous préparerons éventuellement une version en format PDF dynamique (qui peut être remplie à l’écran). ...