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FCA

North Shore Health Region v. Canada, 2008 FCA 2

It imposes GST on most supplies of goods and services, calculated as a percentage of the consideration paid. ...
EC decision

Hall v. MNR, 70 DTC 6333, [1970] CTC 510 (Ex Ct), briefly aff'd 71 DTC 5217 (SCC)

Amyot before the Tax Appeal Board was rather vague on the point, apparently the contention of the other partners is that had they known at the time, as they claim the deceased already did, that he would not be receiving the Métro contract involving some $35,000, of which they would receive 50%, they would not have agreed to pay him $35,900 on his withdrawal from the partnership, even though. his share of this potential $35,000 had not been taken into consideration in arriving at the amount he was to be paid, because Amyot and Derome, who are also surveyors, put into the partnership earnings which they had received in this capacity, which Mr. ...
FCA

Pechet v. Canada, 2009 DTC 5189, 2009 FCA 341

  [24]      The Judge discussed the appellant’s perpetuity argument as a contextual consideration. ...
TCC

The Toronto-Dominion Bank v. The Queen, 94 DTC 1261, [1994] 1 CTC 2615 (TCC)

The recommendation by Jones to his divisional supervisor was that this warranted consideration. ...
FCA

Klassen v. Canada, 2007 DTC 5612, 2007 FCA 339

According to Counsel, there is no requirement in the ITA that a qualifying institution confer any particular type of degree and as MSU-Bottineau is by name a university and grants a degree, the fact that it does not confer a bachelor’s degree is not a relevant consideration for denying the credits claimed ...
FCTD

Vine Estate v. The Queen, 89 DTC 5528, [1990] 1 CTC 18 (FCTD)

Subsection 15(1) adds "the amount or value" of a benefit to the income of a taxpayer, and, as can be seen in Youngman, Century 21 Ramos Realty, Board man and Reid, all supra, the concept of “benefit” is limited to monetary considerations. ...
TCC

Lauger c. La Reine, 2008 DTC 3741, 2007 TCC 650 (Informal Procedure)

    [93]     Another consideration that leads me to believe that FTN was not carrying on a business is that FTN does not appear to have kept the benefits stemming from the research work. ...
FCA

Hudon v. Canada, 2001 DTC 5630, 2001 FCA 320

., for this Court, rejected these considerations. He made the following comment (at page 6030 of the reported decision) which the Tax Court judge reproduced at paragraph 101 of his reasons (96-4115(IT)G). ...
TCC

Placements Marcel Lapointe Inc. v. MNR, 93 DTC 821, [1993] 1 CTC 2506, [1993] 1 CTC 2261, [1993] DTC 809 (TCC)

Marcel Lapointe agreed to provide these services personally in consideration of a sum of $500 per week. 3.12 A questionnaire dated December 28, 1988 put to Mr. ...
EC decision

Southam Business Publications Ltd. v. MNR, 66 DTC 5215, [1966] CTC 265 (Ex. Ct.), briefly aff'd 67 DTC 5150 (SCC)

This was based, in our final consideration, on two factors. One that 5,000 subscribers were worth $10 each, which would be the equivalent cost of getting them, and secondly $100,000 on advertising revenue annually via 25 per cent which is the standard commission cost on securing advertising.” ...

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