Search - consideration
Results 6081 - 6090 of 28818 for consideration
TCC
Serafino Tiberio and Vitangela Tiberio v. Minister of National Revenue, [1990] 2 CTC 2545, 91 DTC 17
This group of our citizens is entitled, I think, to special consideration at this time. ... There would then follow a consideration of the distinction under the provisions of s. 1 of the Charter. ... “involved a consideration of the reasonableness and fairness” of section 15(1). ...
TCC
Donald Maclean Lindsay and Jacqueline Lindsay v. Minister of National Revenue, [1990] 1 CTC 2245, 90 DTC 1085
On that date Gertrude's equity in the property was not less than $80,000; (o) Gertrude transferred her equity in the property to the appellant and Jacqueline without consideration; (p) the stated consideration for the transfer referred to in paragraph 3(n) was $140,000 which, on the affidavit of consideration, was allocated $72,000 to mortgages assumed and $68,000 to other valuable consideration. ... Initially they were taken aback, but after one or two further discussions and some consideration they accepted Friesen's terms. ... It discloses, inter alia, that a portion of the consideration for the transaction was allocated to the assumption of a mortgage in the amount of $72,000. ...
TCC
Atlas Industries Ltd. v. Minister of National Revenue, [1986] 2 CTC 2392, 86 DTC 1756
Of course none of the sources were capital gains and this eliminated consideration of subparagraph 129(4)(a)(i). ... From the evidence and after a careful consideration of the submissions of counsel, it would appear that items 3 and 4 above referred to, namely: 1972 1973 3. ... I am satisfied that the facts under consideration do not place the relevant property within it. ...
TCC
Hallbaurer v. R., [1997] 1 CTC 2428, [1997] DTC 767
Hallbauer identified himself as one of the transferees and described “the true consideration paid by us”. ... The consideration paid by Mr. Meister was a combination of shares and cash. ... Proceeds of disposition are defined by the sale price of the property sold, not the amount or type of consideration received. ...
TCC
Cribb-McKeown v. R., [1998] 3 CTC 2458, 98 DTC 1647
As was observed by the Appellant, this problem was under constant consideration and a lawyer, Arnold, was consulted. ... Thus, the form of the transfer and the consideration paid should be ignored as irrelevant. ... By Resolution, the sum of $725,600 was fixed as the aggregate consideration for the issuance of the aforesaid special shares. ...
FCA
Canada (Attorney General) v. Lloyd, 2022 FCA 127
Moreover, as noted by the Federal Court, the Assistant Commissioner did not explain why these opinions supersede every other consideration that bore on his decision, including the characterization of Ms. ... As stated by the Federal Court, the Assistant Commissioner had an obligation to consider and grapple with other considerations before coming to its decision. ... Lloyd’s tumultuous relationship with the Agency imposed on the Assistant Commissioner a heightened responsibility to provide reasons covering all relevant considerations, including the consequences of his decision. ...
FCTD
Roy J Perini v. Her Majesty the Queen, [1978] CTC 164, 78 DTC 6080
But the real question is still what is its intrinsic character, and in the consideration of this question a description due to the authority under which it is paid may well mislead.” ... It is merely an adjustment of the nominal consideration for the transfer. ... Clearly, this policy could not be taken into consideration if it were contrary to the provisions of the Act. ...
EC decision
Avril Holdings Ltd. v. Minister of National Revenue, [1969] CTC 397, 69 DTC 5263
A memorandum signed by officers of the companies on March 2, 1962 acknowledged and confirmed that the said book value and consideration payable was $194, 716. 91. ... As partial consideration, the purchaser assumed liabilities of the vendor of $732,462.00. ... It is not so much the nature of the property which is taken into consideration but the fact that the property is giving rise to capital cost allowance. ...
EC decision
Nicholson Limited v. Minister of National Revenue, [1945] CTC 263
This requires consideration of the various items involved in the assessment and whether they have been properly included. ... He allowed the appeal and referred the matter back to the Minister for further consideration of reasonable allowance within the Act. ... The matters referred to by counsel are among the very considerations that Parliament has left to the discretion of the Minister. ...
Technical Interpretation - External
3 November 1997 External T.I. 9714465 - GIFTS
Principal Issues: Whether or not certain dispositions of property to a registered charity for some consideration can result in a gift. ... As previously determined, the assumption of a mortgage by the recipient of the property is consideration Mr. ... The proceeds from the sale of shares for an amount equal to the shares' adjusted cost base in your first situation would constitute valuable consideration. ...