Search - consideration
Results 16081 - 16090 of 28818 for consideration
TCC
Gestion Sersec Inc. And Lise Gosselin Huot v. Minister of National Revenue, [1993] 1 CTC 2229, 93 DTC 497
That would appear appropriate to me, and would produce a result of $406,000. 4.02.2 The income approach seems to me to be the most realistic even though it is indirect: it provides a better indication of the considerations in the minds of investors who are often content with little return on their investment in order to accumulate equity eventually. ...
TCC
Intertan Canada Ltd. v. Minister of National Revenue, [1993] 1 CTC 2311, 93 DTC 354
Subsection 5301(1) of the Regulations was amended by P.C. 1985-2277, subsection 16(1), to create the new definition of "first instalment base" as follows: 5301.(1) Subject to subsections (6) and (8), for the purposes of subsections 157(4) and 161(9) of the Act, the “first instalment base” of a corporation for a particular taxation year means the product obtained when the tax payable by the corporation under Part I of the Act, computed without reference to sections 123.3 to 123.5, 127.2 and 127.3 thereof and before taking into consideration any amount referred to in any of subparagraphs 161 (7)(a)(i) to (vii) thereof that was excluded or deducted, as the case may be, for its taxation year immediately preceding the particular year, is multiplied by the ratio that 365 is of the number of days in that preceding year. ...
TCC
David Robinson v. Minister of National Revenue, [1993] 1 CTC 2406, 93 DTC 254
It was made without corporate or shareholder knowledge, authorization or intent and without passage of even a scintilla of consideration. ...
TCC
Angelo Testa and Libera Testa v. Her Majesty the Queen, [1993] 1 CTC 2722, 93 DTC 413
For any consideration of possible commercial uses, Mr. Folstad would have had to make assumptions as to the type of rezoning that might be permitted after V-Day; the type of building that might be constructed in accordance with the new zoning; and the future year (holding period) when the new zoning might take effect. ...
FCTD
Louise Darch and Gail Wright v. Her Majesty the Queen, [1992] 2 CTC 128, 92 DTC 6366
These agreements each provided that for a consideration of $5,000 (which could be applied to the ultimate purchase price) each of the plaintiffs had a 60-day option to purchase 70,000 shares from the other party to the respective agreements for 80 cents per share. ...
SKQB decision
Sun Life Assurance Company of Canada v. Her Majesty the Queen in Right of Canada Represented by the Department of National Revenue and Charles Young., [1992] 2 CTC 315
Although his consideration of the constitutionality of that section was not strictly essential to his decision in the case itself as he pointed out at page 139 (D.T.C. 6178), paragraph 20, all of what Chief Justice Scott said is, in my view, directly applicable for the purposes of the present first question. ...
TCC
Cline Associates London Limited v. Minister of National Revenue, [1992] 2 CTC 2581, 92 DTC 2209
Summary In the end analysis, I conclude that in making the payments at issue Cline, supra, Was not acting in an unreasonable or irrational way, lacking adequate consideration for its own commercial interest. ...
TCC
Rose Marie Curylo and Edward Curylo v. M.N.R., [1992] 1 CTC 2389, 92 DTC 1250
On December 21, 1984, 281215 issued research and development demand debentures in the principal amount of $4,240,920 to purchasers for a total consideration of $7,188,000. ...
ABPC decision
Her Majesty the Queen v. Ulla Mackenzie, [1991] 2 CTC 142
This involves consideration of what a reasonable man would have done in the circumstances. ...
FCTD
Florence A. Hawkins v. Her Majesty the Queen, [1991] 2 CTC 148
I would also agree that the fiscal considerations involved as far as taxes are involved are not at opposite poles. ...