Search - consideration
Results 12371 - 12380 of 28852 for consideration
FCA
Hallbauer v. R., 98 DTC 6275, [1998] 3 CTC 115 (FCA)
Couzin, “Income Tax Considerations in Corporate Financing” Canadian Tax Foundation, Corporate Management Tax Conference, 1986; G.W. ... [The problem of mortgagees buying in under their own power of sale, and at a nominal price, raises other considerations: see generally J.T. ...
TCC
Pluri Vox Media Corp. v. The Queen, 2011 DTC 1175 [at at 960], 2011 TCC 237 (Informal Procedure), aff'd on different reasoning, supra
No exhaustive list has been compiled and perhaps no exhaustive list can be compiled of considerations which are relevant in determining that question, nor can strict rules be laid down as to the relative weight which the various considerations should carry in particular cases. ...
FCTD
Western Union Insurance Co. v. The Queen, 83 DTC 5388, [1983] CTC 363 (FCTD)
He concluded that the bonus ought to “be regarded as consideration for providing the loan and was therefore earned in 1974, the year during which the financing took place”. ... The learned judge said that, if the bonus was the sole consideration for the loan, there would appear to be a very strong probability that it was interest, but where there was interest plus a bonus, then the bonus was to be considered as an inducement to the lender to incur the risk and “the lump sum payment, not being payment merely for the use of the money, is, in the absence of very special circumstances, a profit from an adventure in the nature of trade”. ...
FCA
Lord's Evangelical Church of Deliverance and Prayer of Toronto v. Canada, 2004 DTC 6746, 2004 FCA 397
The appellant therefore argues that no consideration was given by the Minister to the proposed remedial steps before the revocation decision was made. ... Indian Head School Division No. 19, [1990] 1 S.C.R. 653 at 669, where L'Heureux-Dubé J. stated for the majority: The existence of a general duty to act fairly will depend on the consideration of three factors: (i) the nature of the decision to be made by the administrative body; (ii) the relationship existing between that body and the individual; and (iii) the effect of that decision on the individual's rights. ...
EC decision
Sazio v. MNR, 69 DTC 5001, [1968] CTC 579 (Ex Ct)
Sazio Limited (hereinafter called the Company) by letters patent dated April 2, 1964 with an authorized capital of 3,600 preference shares of the par value of $10 each and 4,000 common shares without nominal or par value which common shares might be issued for an aggregate consideration of $40,000. ... The company then hires the artiste out to whomsoever requires his services and itself obtains the consideration for them.... ...
FCTD
DiLorenzo v. The Queen, 82 DTC 6085, [1982] CTC 151 (FCTD)
NOW THEREFORE in consideration of these presents and other good and valuable consideration, the undersigned do covenant, promise and agree in favour of the Minister as follows: 1. ...
TCC
Keating v. The Queen, 2005 DTC 743, 2005 TCC 296 (Informal Procedure)
I believe that according to the principles in Rich, the predominant consideration is still the ability of the debtor to repay the debt in whole or in part. ... The Respondent's attempt to characterize these staged payments amounting to $180,000.00 under the oppression action as somehow a settlement of spousal support is completely unsupported by the oral and documentary evidence. [23] Although the only consideration for the matrimonial action was the settlement of the oppression action, there are two distinct sets of legal accounts from the one law firm. ...
TCC
Tibilla v. The Queen, 2013 DTC 1174 [at at 946], 2013 TCC 215, aff'd 2014 DTC 5125 [at 7322], 2014 FCA 227
Moreover, the CRA included the capital gain in income for 2007 instead of 2008 on the basis that the disposition of the property occurred in December 2007 and the appellant received the consideration for the property at that time ... The consideration for the sale was $285,000, which the vendor (the appellant) acknowledged having received from the purchaser and for which complete discharge was given (see deed of sale, Exhibit R-1, Tab 14, page 6 “Prix”). ...
FCTD
Mendels v. The Queen, 78 DTC 6267, [1978] CTC 404 (FCTD)
To determine the propriety of the deduction of the management fee consideration was given to the question whether genuine business reasons existed for the payment of the management fee. ... In the consideration of this question it is of paramount importance to consider what bona fide business purpose is sought to be achieved and if any such purpose was achieved. ...
TCC
Cranston v. The Queen, 2010 TCC 414, 2010 DTC 1280 at 3948
However, it differs somewhat from a consideration of the possible application of issue estoppel in that the consideration is focused on preserving the integrity of the adjudicative process more so than on the status, motive or rights of the parties. [30] Relitigation should be avoided unless it is in fact necessary to enhance the credibility and effectiveness of the adjudicative process. ...