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TCC

Ronald Timpson v. Minister of National Revenue, [1985] 2 CTC 2114, 85 DTC 446

However, it must be remembered that what is under consideration in this case is the relative importance of farming as a source of income. ...
TCC

Ronald J Wiebe, Raymond R Bastien v. Minister of National Revenue, [1985] 2 CTC 2346, 85 DTC 635

The Respondent further submits that there was no consideration paid for any revocation, cancellation or change of the Appellant's share option. 13. ...
TCC

Les Installations De L’est Inc, Les Entreprises Savino Inc v. Minister of National Revenue, [1985] 2 CTC 2446, 85 DTC 660

I agree that to some degree there was evidence contradicting some of the Minister's minor assumptions regarding separate telephones, bookkeeping services etc, for the two companies; and that indeed the testimony of the witnesses shows little evidence of direct consideration of income taxes at incorporation. ...
FCTD

Consumers Glass Company Limited v. Minister of National Revenue, Deputy Minister of National Revenue for Customs and Excise, Andrew a Bradley and George Schoenhofer, [1985] 1 CTC 15

In any event, there is nothing to indicate that the Board will not give full and proper consideration to all such submissions by the applicant. ...
TCC

Charles a Beghin v. Minister of National Revenue, [1985] 1 CTC 2034, 85 DTC 48

In arriving at his decision and establishing his principle, Mr Justice Cattanach, based himself on the following considerations: In considering the question so posed, I do so on the acceptance of three premises: (1) that the relationship between the appellant and his accountant was that of principal and agent; (2) that the omission and errors of the accountant in preparing the appellant’s tax returns constituted gross negligence on the part of the accountant; and (3) that the appellant did not know of these omissions and errors on the part of the accountant. ...
TCC

George Robinson v. Minister of National Revenue, [1985] 1 CTC 2054, 85 DTC 84

The personal circumstances surrounding and impinging upon a payment for “wages” by a businessman to his wife, would usually lack the normal reciprocal constraints to be found between unrelated parties, and the possible income tax advantage available would be an evident consideration by at least one party to the arrangement. ...
TCC

G D L Simons v. Minister of National Revenue, [1985] 1 CTC 2116, 85 DTC 105

It was made without corporate or shareholder knowledge, authorization or intent and without passage of even a scintilla of consideration. ...
TCC

Eric Rode, Elizabeth Rode v. Minister of National Revenue, [1985] 1 CTC 2324, 85 DTC 272

In my view the definition of “principal residence’’ contained in paragraph 54(g) is such that considerations as to what can lawfully and effectively be conveyed are irrelevant. ...
TCC

Matador Co-Operative Farm Association Limited v. Minister of National Revenue, [1984] CTC 2046, 84 DTC 1038

In accordance with a buy-sell arrangement among the shareholders of the company, the value of the deceased’s interest in the company was determined giving consideration to the current estimated fair market values of the net corporate assets at the time. ...
TCC

Hopkins Construction (Lacombe) LTD v. Minister of National Revenue, [1984] CTC 2172, 84 DTC 1150

At that point of time, consideration does pass between the vendor and purchaser, and the vendor transfers all his rights, property and interest in the sand or gravel to Alberta Transportation and concurrently grants Alberta Transportation the right to enter on and to explore, prospect, dig, work, excavate and take from his land all sand or gravel necessary. ...

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