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TCC

Denis M. Lee v. Minister of National Revenue, [1990] 1 CTC 2082, 90 DTC 1014

The difference cannot be stated in precise and definite terms, but each case must be determined after all the relevant factors are taken into consideration, but the foregoing indicates in a general way the essential difference. ...
TCC

Carl R. Rahey v. Minister of National Revenue, [1990] 1 CTC 2272, 90 DTC 1053

The appellant may adduce facts constituting a prima facie case which remains unanswered; but in considering whether this has been done it is important not to forget, if it be so, that the facts are, in a special degree if not exclusively, within the appellant’s cognizance; although this last is a consideration which, for obvious reasons, must not be pressed too far. ...
TCC

George E. Waugh, Jerry W. Higgins, K. Michael Lowther, Trevor S. Russell, Constance K. Duncan, Christopher G. Duncan, Ronald Rodrique, Alex Bodnar, Brian Smedley, Robert L. Brewin, Leslie H. Shumka v. Minister of National Revenue, [1990] 1 CTC 2346, 90 DTC 1117

My conclusion after a careful consideration of the reasons given by the learned member of the Tax Appeal Board is that his disposition of the appeal turned on his belief that the applicable provisions of the Income Tax Act should not be construed and applied so as to differentiate between employees in the manner indicated. ...
TCC

D & B Oilfield Contracting Ltd. v. Minister of National Revenue, [1989] 2 CTC 2140, 89 DTC 425

NOW THEREFORE THIS INDENTURE WITNESSETH that in consideration of the premises and the mutual covenants and agreements hereinafter set forth, the parties hereto agree as follows: 1. ...
TCC

Funtronix Amusements Ltd. v. Minister of National Revenue, [1989] 2 CTC 2296

On the other hand, if a much broader consideration of the term "user" found in paragraph (b) of that definition is adopted, it could include owners of the equipment such as the appellant. ...
TCC

Barbara Kostiuk v. Minister of National Revenue, [1989] 2 CTC 2328, 89 DTC 541

Holdings Ltd. to Peter Bodnarchuk in consideration for the settlement of their matrimonial property (Exhibits A-8 and A-9). ...
NBCA decision

Knox Contracting Limited and Harold Hazen Knox v. The Queen, the Minister of National Revenue, the Attorney-General of Canada, the Deputy Attorney-General of Canada, the Attorney-General of New Brunswick, John Byron Clarke and Bernard Gerard Gillis., [1989] 1 CTC 174, 89 DTC 5074

In deciding whether to exercise the right last mentioned, he will be governed by many considerations, dominant among which is the public interest and his duty as an executive officer of the government to administer the Act to the best of his ability. ...
FCTD

Paul Gagné v. Her Majesty the Queen, [1989] 1 CTC 199

For all of these reasons, and in consideration of the burden of proof on the plaintiff, I must dismiss this action with costs. ...
FCA

Her Majesty the Queen v. Wally Fries, [1989] 1 CTC 471, 89 DTC 5240

What was merely an arrangement or unenforceable agreement between the S.G.E.U. and the Liquor Board Employees Agreement Group, once made and communicated to the employees themselves, became an offer to pay in consideration of a service rendered. [1] The appellant, through his counsel, vigorously contested this finding. ...
TCC

Les Manufacturiers De Bijoux L.S.M. Inc. v. Minister of National Revenue, [1989] 1 CTC 2024, 88 DTC 1767

Noël undertook to remain an employee of the company for a period of 50 weeks commencing February 3, 1978 in consideration of a weekly salary of $500 per week. ...

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