Search - consideration
Results 511 - 520 of 626 for consideration
T Rev B decision
Kenneth a Brown v. Minister of National Revenue, [1978] CTC 2447, [1978] DTC 1333
A consideration as well was the industrial park in the Town of Sussex which was assisted by federal grants and offered services which were ‘not available elsewhere at comparable prices. ...
T Rev B decision
Robert B Forward v. Minister of National Revenue, [1978] CTC 2604, [1978] DTC 1455
Dr Small required that, in consideration for being permitted to enter into this arrangement, the appellant make an interest-free loan to Small Company. ...
T Rev B decision
A E Flintoft and William J Flintoft v. Minister of National Revenue, [1978] CTC 2751, [1978] DTC 1543
BETWEEN: JACK LEE LTD, a company duly incorporated under the laws of the province of British Columbia, and having its registered office at 201- 535 Thurlow Street, in the city of Vancouver, in the province of British Columbia; OF THE FIRST PART AND: JACK LEE, public relations man, of 4345 Baker View Street, in the district of North Vancouver, in the province of British Columbia; OF THE SECOND PART AND: YULE MORTGAGE LTD, a company duly incorporated under the laws of the province of British Columbia, and having its place of. business at 700 St Andrews Road, in the municipality of West Vancouver, in the province of British Columbia; OF THE THIRD PART AND: WILLIAM JAMES FLINTOFT, businessman, of 700 St Andrews Road, in the municipality of West Vancouver, in the province of British Columbia; OF THE FOURTH PART WHEREAS Yule Mortgage Ltd (hereinafter called “Yule”) has agreed to lend to Jack Lee Ltd (hereinafter called “the company’’) the sum of $15,000; AND WHEREAS Jack Lee has agreed to personally guarantee the repayment of the said loan of $15,000 to Yule; AND WHEREAS Jack Lee and William James Flintoft are the holders of 50 shares each in the capital stock of the company; AND WHEREAS the financial and business success of the company is wholly contingent upon the continued efforts of Jack Lee for and on behalf of the company; NOW THEREFORE THIS INDENTURE WITNESSETH that in consideration of the mutual covenants and agreements herein contained the parties hereto agree each with the other as follows: 1. ...
T Rev B decision
George Marinis v. Minister of National Revenue, [1978] CTC 2821, [1978] DTC 1609
IT-231, para 4: In determining whether or not either spouse is actively engaged in the business of the partnership, consideration is given to the amount of services rendered and any special expertise that such spouse contributes. ...
T Rev B decision
Jean Morin v. Minister of National Revenue, [1978] CTC 2976, [1978] DTC 1693
According to him, this sum was the lesser of the following two amounts: the above-mentioned $50,302.02 in accounts receivable, and $65,070.44, which he said was the adjusted cost base of his interest in the partnership. (3) According to the respondent, however, the adjusted cost base of the appellant’s interest in the partnership was $28,538.08, which left $21,763.94 in the income for 1972, that is, $50,302.02 less $28,538.08. (4) The difference in the appellant’s and the respondent’s data is explained by the fact that the respondent considered the goodwill to be nil; goodwill is a factor that must be taken into consideration when calculating tax equity pursuant to subsection 26(9) of the Income Tax Application Rules, 1971. ...
T Rev B decision
Hady Construction (1971) LTD v. Minister of National Revenue, [1980] CTC 2135, [1980] DTC 1101
One must turn to a consideration of the situation as it existed in 1974. ...
T Rev B decision
James Taggart v. Minister of National Revenue, [1980] CTC 2322, [1980] DTC 1296
Another consideration the Board member mentions is the mortgage itself. ...
T Rev B decision
Edward C Sargent v. Minister of National Revenue, [1983] CTC 2639
Respondent’s Argument Counsel for the respondent premised his argument on the basis that if the Crown is in a position that it cannot reassess in a statute-barred taxation year, the Board must take into consideration the fact that there may be a loss of tax revenue. ...
T Rev B decision
Philippe Ewart v. Minister of National Revenue, [1978] CTC 2315, 78 DTC 1221
Third question: If this personal income is taxable, is it a consideration which is directly and closely related to the activities of Namofil Inc? ... Because of the conclusions which the Board reached in paragraph 6.8.2, this expense cannot be taken into consideration in the computation of deductible expenses. ... This is an economic and business reality which must be taken into consideration. ...
T Rev B decision
Doris Lillian Gadsden v. Minister of National Revenue, [1983] CTC 2132, 83 DTC 127
Where in a taxation year a taxpayer disposes of an income interest in a trust, (a) except where subsection (3) is applicable, there shall be included in computing his income for the year the proceeds of the disposition; (b) any taxable capital gain or allowable capital loss of the taxpayer from the disposition shall be deemed to be nil; and (c) for greater certainty, the cost to the taxpayer of each property received by him as consideration for the disposition is the fair market value of the property at the time of the disposition. ... Headnotes cannot control the plain meaning of the enactment, though they may, in some cases, be looked upon in the light of preambles if there is any ambiguity in the meaning of the sections on which they throw light”. 2. fl vs Bates and Russell (1952) WN 506—“They (headings) are not to be taken into consideration if the language of the enactment is clear”. 3. ...