Search - consideration
Results 23271 - 23280 of 29012 for consideration
EC decision
Fraser Companies Limited v. The Minister of National Revenue, [1951] CTC 140, [1951] DTC 469
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. ...
TCC
Dirk v. M.N.R, 2024 TCC 95
Dirk in his testimony, it appears that the reason for the change of employer was driven by foreign exchange control considerations. ...
TCC
Caroni v. The King, 2025 TCC 101
Similar considerations apply for 2014 where only $5,000 in income was declared. ...
TCC
Lewis v. M.N.R., docket 96-1638-UI
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. ...
Ruling
2019 Ruling 2018-0761621R3 - Cross-Border Butterfly
Forco 1 will subscribe for shares of Foreign SpincoSub upon its incorporation for cash consideration. 33. ... Foreign SpincoSub will subscribe for Canadian TC Common Shares on its incorporation for nominal cash consideration. ... In consideration for the Foreign Pubco Transfer, Foreign Spinco will: (a) pay cash; (b) issue debt securities; and (c) issue a number of Foreign Spinco common shares, to Foreign Pubco. ...
Miscellaneous severed letter
30 October 1992 Income Tax Severed Letter 2M0333A - Published Version of 1991 Canadian Tax Foundation
One of the considerations in determining the reasonableness of the profit allocation is the personal use of the partnership property by a partner. ... The client's financial situation will be taken fully into consideration in arriving at an arrangement based upon his or her ability to pay. ... If the year is still open (not statute-barred), the department can raise other issues and, if noted, will refer them to Audit or Assessing for consideration. ...
SCC
Hickman Motors Ltd. v. Canada, 97 DTC 5363, [1997] 2 S.C.R. 336, [1998] 1 CTC 213
Therefore, the CCA deduction is allowable. 100 Both the Trial Division and the Court of Appeal failed to take the revenue into consideration and, in determining whether the equipment-related assets met the requirements of Regulation 1102, made incorrect inferences, asked the wrong questions of law and applied the wrong test, which constitute reviewable errors of law. ...
TCC
Brasserie Futuriste de Laval Inc. c. La Reine, 2006 TCC 503
Morand, are another consideration tied to unreported sales. Furthermore, the evidence reveals that some employees' wages were paid out of income that was not on the books, and points to other expenses paid for in cash (Exhibits I‑11 and I‑12) ...
TCC
Dipede v. The Queen, 2004 TCC 100
This is an important consideration on both questions as to whether or not he was capable of understanding that he was a director and on the due diligence test. [156] Counsel admitted that the Appellant looked at some construction drawings, ordered materials and called the union. ...
FCTD
Bessette v. Quebec (Attorney General), 2019 FC 393
[94] Since consideration of infringement and validity issues is, however, dependent on the construction of the patent claims in suit (Whirlpool Corp. v Camco Inc, 2000 SCC 67 at para 43 [Camco]), I will first interpret the contentious claims of each patent. ... Section 87 reads as follows: 87 (1) Subject to subsection (2), any claim that includes all the features of one or more other claims (in this section referred to as a “dependent claim”) shall refer by number to the other claim or claims and shall state the additional features claimed. 87 (1) Sous réserve du paragraphe (2), la revendication qui inclut toutes les caractéristiques d’une ou de plusieurs autres revendications (appelée « revendication dépendante » au présent article) renvoie au numéro de ces autres revendications et précise les caractéristiques additionnelles revendiquées. (2) A dependent claim may only refer to a preceding claim or claims. (2) La revendication dépendante peut seulement renvoyer à une ou plusieurs revendications antérieures. (3) Any dependent claim shall be understood as including all the limitations contained in the claim to which it refers or, if the dependent claim refers to more than one other claim, all the limitations contained in the particular claim or claims in relation to which it is considered. (3) La revendication dépendante comporte toutes les restrictions contenues dans la revendication à laquelle elle renvoie ou, si elle renvoie à plusieurs revendications, toutes les restrictions figurant dans la revendications [sic] ou les revendications avec lesquelles elle est prise en considération. [175] By thus adding features to those claimed in the claim on which it depends, the dependent claim not only clarifies but also, in a way, limits the scope of the monopoly covered by the independent claim. ... In the same vein, this Court, in Janssen-Ortho Inc v Novopharm Ltd, 2006 FC 1234 at para 113 (aff’d 2007 FCA 217, leave to appeal to SCC refused, 32200 (December 6, 2007)), recalled that, not being a “scientific body”, it must “ take the facts of the case, the opinions of the experts and the circumstances as presented into consideration and come up with a weighed decision” on obviousness [emphasis added]. ...