Search - consideration

It reads as follows: 5301(1) Subject to subsection (6) and (8), for the purposes of subsections 157(4) and 161(9) of the Act, the “first instalment base” of a corporation for a particular taxation year means the product obtained when the tax payable by the corporation under Part I of the Act, computed without reference to sections 123.3 to 123.5, 127.2 and 127.3 thereof and before taking into consideration any amount referred to in any of subparagraphs 161 (7)(a)(i) to (vii) thereof that was excluded or deducted, as the case may be, for its taxation year immediately preceding the particular year, is multiplied by the ration that 365 is of the number of days in that preceding year. ...

Vitellaro, dated March 15, 2004, and the amount of the appellants' tax indebtedness to the CCRA are taken into consideration.                                                                                                                                    ...

The Tax Court of Canada judge had allowed the application, on the basis that the accountant's efforts to deal with the problem directly with the Department of National Revenue could be taken into consideration and that, accordingly, the application for an extension was filed as soon as the circumstances permitted. ...

Further, counsel made reference to the doctrine of relation back, a doctrine which doesn't seem to have any bearing on the circumstances now under consideration. ...

That requires a complete consideration of all of the facts relating to the income, which must include but cannot be limited to the formal legal structure through which the income is received. ...

Under these contracts, the Appellant makes a total contribution of $25,500, in consideration of which Canada Russia Lottery Inc. must pay the Appellant 5.5% of the gross revenue from the operation of a lottery terminal in St.  ...

This consideration, coupled with the fact that no copy of the notification of confirmation was either transmitted to the Court under subsection 170(2) or produced in evidence as well as the significant and unexplained omission of any reference to a date of mailing of the alleged notification, leads me to the conclusion that, on the basis of the evidence before me on this motion, no notification was sent on December 7, 1989 or at any other time. ...

After careful consideration of the record and of counsel’s written and oral submissions, I propose to dismiss the appeal. ...

It is his duty, if the same issues of fact arise for determination in another case, to reach his conclusions with regard thereto on the evidence adduced in that case after giving full consideration to the submissions with regard thereto made on behalf of the parties in that case. ...

.* [1] Counsel for the applicants indirectly raised another point which deserves more favourable consideration. ...