Search - consideration

One was to fund the R&D of Amcor effectively; and secondly, would provide meaningful financial consideration being returned to Amcor far in excess of the money that was sent up. ...

Ward, “Tax Considerations Relating to the Purchase of Assets of a Business,” in Corporate Acquisitions, Reorganizations and Liquidations, 1972 Corporate Management Tax Conference 22–50. [39] MacMillan Bloedel, paragraph 8 (CTC). [40] Sullivan, pages 40 and 41. [41] Canada Trustco, paragraph 12. [42] Sullivan, page 326. [43] The Bank of Montreal v. ...

C.R. 93 at 97; [1953] C.T.C. 203 at 207: “... the true position is that on an appeal to this Court from a decision of the Income Tax Appeal Board, whether the taxpayer or the Minister is the appellant, the assessment under consideration carries with it a presumption of its validity until the taxpayer establishes that it is incorrect either in fact or in law.” ...

Furthermore, one has to keep in mind that the Minister has the responsibility to set out the case they are making against a taxpayer by fully setting out the assumptions of fact made by the Minister in making the assessment. [157] In this appeal, the Minister alleges a complicated tax scheme put in place by the Appellant for the benefit of numerous clients to allow them to sell assets without paying tax on the proceeds of disposition, in consideration for a fee, which was not reported by the Appellant as income. ...

Summary of the Proceedings [12] The facts summarized below were taken into consideration by the Court for issuing this Order. 2016 [13] On January 5, 2016, the Respondent filed a motion to quash John Doe’s appeal with respect to the 2009, 2010 and 2011 taxation years on the basis that John Doe had not met the requirements in order to file a valid appeal. [8] The hearing of the motion was scheduled for January 29, 2016, in Vancouver. [14] On January 22, 2016, the Court was made aware of the nature of John Doe’s hospitalization. ...

On the foregoing considerations and in the light of the other provisions of the Act, I am unable to interpret section 3 as Mr. ...

It was submitted on behalf of appellant that its claim for a rate of standard profit of 10% was based on the following considerations: " (a) 1940 costs and selling prices for sulphite and groundwood pulp, paper-board, lumber, lath, shingles and ties. ...

Dirk in his testimony, it appears that the reason for the change of employer was driven by foreign exchange control considerations. ...

And then just getting back to-- and any documents that they provided, were they taken into consideration? ... That information would have been taken into consideration in doing the ruling. ... SO, what you're saying by that is there's a lot of people who were given consideration based on their own independent facts that aren't here today--- A.          ...