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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. ...
TCC

Gary Yott, Arcade Du Vieux Montréal Ltd. And Rideau Arcades Ltd. v. Minister of National Revenue, [1991] 2 CTC 2001, 91 DTC 611

This Court does not consider that there is a valid consent to judgment unless a written document, signed by the parties or their counsel, is produced, or the consent is mutually expressed in oral submissions before the Court; otherwise, the Court does not take the consent into consideration. ...
TCC

Henrietta J. Cedergren v. Minister of National Revenue, [1991] 2 CTC 2068, 91 DTC 920

The fact that there is no joint ownership is not by itself determinant though it would seem that in a partnership, this factor would be taken into consideration in the sharing of expenses and income, and it has not. ...
TCC

Daniel A. Shefner Estate v. Minister of National Revenue, [1991] 2 CTC 2088, 91 DTC 333

There can be no doubt that the payment in question made by Shefner was dictated by business considerations. ...
TCC

Raymond Kirby and the Estate of Daniel Lee v. Minister of National Revenue, [1991] 2 CTC 2639, 91 DTC 1453

These decisions are different from the consideration Joyal, J. of the F.C.T.D. had before him in First Fund Genesis Corporation v. ...
ABCA decision

Lloyds Bank Canada v. International Warranty Company Limited and Attorney General of Canada v. International Warranty Company Limited, [1990] 2 CTC 360

Court of Appeal had for consideration a claim for priority under a provincial statute, which constituted a claim by an employee for wages, if certified under the act, as being payable “in priority over any other claim or right—including—every mortgage of real or personal property". ...
TCC

Reine Laine v. Minister of National Revenue, [1990] 2 CTC 2025, 90 DTC 1485

" Even though they are part of the contract of employment, the 57 days of vacation and so on must be considered as secondary (even though they are necessary secondary considerations) in relation to the days of work, which are primary. ...
TCC

The Galway Family Trust v. Minister of National Revenue, [1990] 2 CTC 2486, 90 DTC 1913

Phillips thought that the 1972 sale was not an indication of value for 50 per cent of Langdon's shares in 1974 because part of the consideration in 1972 was the release of substantial bank guarantees. ...

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