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T Rev B decision

R. v. H. Griffiths Co., 76 DTC 6261, [1976] CTC 454, [1975] C.T.C. 2120 (FCTD)

He further stated that the object of the acquisition of Hartwil was to improve the profit potential of the appellant company and that no consideration whatsoever was given to building up Hartwil's financial position to pay dividends. ...
FCA

Universal Timber Products Ltd. v. The Queen, 74 DTC 6413, [1974] CTC 499 (FCA)

The particular document to which the learned judge attributed a great deal of weight, that is to say the agreement of July 1967 (Exhibit 4) in which a consideration of $100,000 is expressed as being for transfer of the interest of the appellant and Phillips and Lee in the timber harvesting licence which had not yet been granted but which was then expected to result from the joint application made in January 1967, is but one among a number of documents of some importance in resolving the present problem. ...
FCTD

Tahsis Co. Ltd. v. The Queen, 79 DTC 5328, [1979] CTC 410 (FCTD)

Fluctuations before December 31, 1971, whether resulting in gains or losses, are not to be taken into consideration. ...
FCA

725685 Alberta ltd. v. Canada, 2009 DTC 6027, 2009 FCA 194

  [5]                The Tax Court Judge found that the appellant’s ordinary business in the years under consideration did not include money lending. ...
TCC

Pellerin c. La Reine, 2006 DTC 3341, 2006 TCC 383 (Informal Procedure)

  [3]      The evidence discloses that these were amounts that her son, a victim of a major accident, paid her in consideration of the care and attention that she gave him due to a significant and permanent partial disability involving very serious after-effects. ...
TCC

Brad-Lea Meadows Ltd. v. MNR, 90 DTC 1269, [1990] 1 CTC 2306 (TCC)

The consideration of the affiliation fee is the sole issue in this appeal. ...
FCTD

Re Stern, 85 DTC 5002, [1984] CTC 647 (FCTD)

Thus, the question is large, and the consideration of adaptation of the rules is not out of the question. ...
FCTD

Usarco Ltd. v. A.G. Canada, [1980] CTC 484, 80 DTC 6381 (FCTD)

In our opinion, the principal consideration which should govern the exercise of the discretion under Rule 401 is whether the defendant has prima facie raised sufficient doubt as to the regularity of the proceedings or the jurisdiction ratione personae of the Court that justice requires he be permitted to appear in such a manner as to avoid any waiver of his objections. ...
TCC

Bertram v. The Queen, 93 DTC 1251, [1993] 2 CTC 2982 (TCC)

McRae, for no other consideration, his option to purchase 44,500 shares from Edgewater for 16¢ per share. ...
TCC

Hewitt v. MNR, 89 DTC 451, [1989] 2 CTC 2278 (TCC)

If the single cash payment out of the Plan had been long delayed, or the amount payable had been spread out over a period of time in a series of payments, other considerations would arise as to (i) whether a portion of the amount received accrued or was earned while the appellant was resident in Canada; or (ii) whether the payments were a "superannuation or pension benefit" within the meaning of the Income Tax Act. ...

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