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Results 191 - 200 of 636 for consideration
EC decision

Judgment Accordingly. Royal Trust Company and Angus Et Al. v. Minister of National Revenue, [1954] CTC 147

Chipman and on the residuary beneficiaries in her will were under consideration. ... Cartwright and Fauteux, JJ. stated that they regarded this question as difficult and doubtful, and added: “If it were necessary to decide this question, careful consideration would first have to be given to the appellant’s argument that the wide terms in which the power given to Dr. ... The question under consideration there was whether there was a passing on the death and that judgment, of course, is not directly applicable to the instant case. ...
EC decision

Anglo-Canadian Oil Company, Limited v. The Minister of National Revenue, [1947] CTC 47, [1946-1948] DTC 950

The problem for consideration, therefore, is whether the costs of and incidental to the drilling of the well are costs of installing. the casing itself. ... In the instant case there seems to be no doubt that all the expenses incurred were capital costs but it is not all capital costs that are taken into consideration in allowing the deductions under sec. 90, but only those specifically defined in the section. ... While the President was considering a different section of the Act, he did, in fact, give consideration to the problem as to whether development costs included costs of the well and found that the hole in the ground through which oil is recovered was plant and equipment. ...
EC decision

Minister of National Revenue v. Robert P. Ouellette an John E. Brett, [1971] CTC 121, 71 DTC 5094

Blauer’s version is that at the time the Place Ville Marie building development in Montreal was under consideration nearly all the engineers in Montreal wanted the opportunity of participating in such an important project. ... This is, of course, highly speculative, but would be one of the many complex possibilities which the parties and their counsel at the time would have had to give consideration to in arriving at a settlement. ... He admits, nevertheless, that he examined the agreement and advised his clients to sign it even though it did give goodwill as the consideration for which the $75,000 referred to in the agreement was paid. ...
EC decision

Western Leaseholds & Western Minerals v. Minister of National Revenue, [1958] CTC 257, 58 DTC 1128

Verner by letter dated October 4, 1944, over some 2,300 acres in consideration of the payment of $1,146.35 (Exhibit 34). ... In my view, no distinction can be drawn between the five items of profit now under consideration. ... But the magnitude of a transaction is not an entirely irrelevant consideration. ...
EC decision

Judgment Accordingly. Lawrence B. Scott v. Minister of National Revenue, [1960] CTC 401

The consideration for the transfer was 256 shares of Alsa Holdings Limited. At about the same time, Capitol Petroleums Limited and Mammoth Petroleums Limited were incorporated and Tabor transferred 128 of the shares of Alsa, held by him, to Capitol, in consideration of 800,000 shares of that company, and the other 128 to Mammoth in consideration of 800,000 shares of that company. ... The present case raises the question as to what is meant by ‘‘the day of an original assessment’’ in subsection (4), which in turn involves consideration of what is an assessment within the meaning of Section 46 and when it is made. ...
EC decision

The Governors of the University of Toronto, One of the Beneficiaries Under the Last Will and Testament of Dr. John $. Chisholm, Deceased v. Minister of National Revenue, [1950] CTC 41, [1949-1950] DTC 738

The sole matter for consideration, therefore, is the claim of the appellant that the gifts to it fell within the ambit of section 7(1) (e) and that, therefore, they are totally exempt from duty. ... This, however, appears to be for information purposes only, no doubt being a matter for consideration when additional funds are asked for by the Board from the Province. ... A consideration of subsections 7(d) and (e) (supra) suggests very strongly that Parliament wished to draw a distinction between two different categories of bequests and to treat them in a different way. ...
EC decision

MNR v. Taylor, 56 DTC 1125, [1956] CTC 189 (Ex Ct)

The considerations that led him to the transaction were fully brought out in the competent cross-examination to which he was subjected by Mr. ... There were several considerations that impelled him to this decision. ... It is plain that the respondent had no considerations of a capital nature in mind. ...
EC decision

Maurice Samson v. Minister of National Revenue, [1943] CTC 47, [1941-1946] DTC 610

The claim involved a consideration of subsection 8(a) of section 3 of the Income War Tax Act, as amended by 13-14 Geo. ... There remains for consideration one further section of the Income War Tax Act. ... The Order-in-Council now under consideration comes within that statement. ...
EC decision

Minister of National Revenue v. Joichi G. Kato, Rupert M. Clare, Ian D. Dickens, Estate of James Gibson, Charles Lefebvre,, [1969] CTC 492, 69 DTC 5308

Kato after giving the matter serious consideration and relying on the advice and description of the land given him by Mr. ... What the Court is here primarily concerned with is the reasonableness, or otherwise, of the amount regarded by the respondent as the consideration for disposition of the building, within the context of Section 20(6) (g) of the Act. ... The respondent regarded $419,647 as the portion of the purchase price of $1,850,000 that can reasonably be regarded as being the consideration for the disposition of the building. ...
EC decision

Isadore Weinstein v. Minister of National Revenue, [1968] CTC 357, 68 DTC 5232

On October 6, 1959 the appellant sold all his interest in the said parcel of land for a total consideration of $53,750. ...

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