Search - consideration
Results 21951 - 21960 of 28970 for consideration
TCC
Walters v. R.|, [1999] 1 CTC 2211, 99 DTC 363
That is what the Court must do when giving consideration to the element of profitability. ...
TCC
Pedwell v. R., [1999] 1 CTC 2431, 99 DTC 63
Peacock’s daugh ters was the price or consideration the numbered corporation was prepared to pay to obtain severance of its lots by testamentary devise rather than proceeding to hearings before the local town council and possible the OMB. 5 5(1976), 15 O.R. (2d) 576 (Ont. ...
TCC
Oerlikon Aérospatiale Inc. v. R., [1998] 4 CTC 2821, 97 DTC 694
At page 5 of his report, this expert acknowledged that there is a difference between an advance in the sense of a loan and an advance in the sense of a payment on account: [TRANSLATION] To establish an accounting distinction between a payment on account and a loan or an advance in the sense of a loan, the following elements may be considered:- a payment on account is not usually repayable in cash, whereas a loan is;- a payment on account does not generally bear interest, whereas a loan may or may not bear interest;- the consideration for a payment on account is in the form of services rendered or goods delivered, whereas the loan is subject to repayment;-when the service is rendered or the goods delivered, the payment on account is entered as revenue, whereas a loan is not entered as revenue, except in rare instances where the lender agrees to waive the debt. ...
FCTD
Ford v. Canada (Revenue Agency), 2022 FC 1077
I agree with the respondent, but the Circular provides additional and separate considerations for the Minister’s analysis under the particular subsection at issue. [58] I therefore conclude that the immediate benefits of the applicant’s requests for relief under the two subsections are not identical. ...
FCA
DR H Hoyle Campbell v. Her Majesty the Queen, [1979] CTC 279, 79 DTC 5202
It was this consideration that led the appellant to enter into an employment contract with the hospital corporation by which he agreed in effect to limit his earnings from the performance of medical services so as to leave the hospital with sufficient working capital. ...
T Rev B decision
Pierre Tremblay v. Minister of National Revenue, [1979] CTC 2631, 79 DTC 305
Cette règle d’or, qui s’applique depuis un siècle et demi, doit également être prise en considération dans la présente cause. ...
FCTD
Hillsdale Shopping Centre Limited v. Minister of National Revenue, [1977] CTC 402, 77 DTC 5256
There is no doubt that serious consideration was given to this location much earlier though no firm decision may have been taken. ...
FCTD
Clemow Realty Limited v. Her Majesty the Queen as Represented, [1976] CTC 129, [1976] DTC 6094
While this is one element to consider, the absence of income from the property is not a principal consideration in determining whether it was purchased for development with the secondary intention of reselling at a profit if this could not be accomplished, or as a pure investment. ...
TCC
Gestion M.-A. Roy Inc. v. The King, 2022 TCC 144, aff'd 2024 CAF 16
They stated that the benefit [translation] “must depend on practical and realistic considerations and cannot include hypothetical or notional situations”. ...
T Rev B decision
Donald G Wilson Et Al v. Minister of National Revenue, [1974] CTC 2219
If it was in their minds—and it is only speculation on my part—it would not have been bad consideration, in any event. ...