Search - considered

Filter by Type:

Results 11231 - 11240 of 14772 for considered
TCC

Louis Goodman v. Minister of National Revenue, [1986] 1 CTC 2468, 86 DTC 1367

(c) Even before the three-month period was up for closing the deal, he had signed a new ten-year lease with Consumers Distributing Company Limited (which he considered a first class tenant at the time) for $40,000 per year on a net-net-net lease basis — a considerable improvement. ...
TCC

I.S.E. Canadian Finance Ltd. v. Minister of National Revenue, [1986] 1 CTC 2473, 86 DTC 1344 (TCC)

Therefore it must be considered that all its activities were properly attributed to income account and correctly treated on an accrual basis. ...
TCC

Paul Viau v. Minister of National Revenue, [1986] 1 CTC 2570, 86 DTC 1437

Act in force on November 12, 1981. 56. (1) Without restricting the generality of section 3, there shall be included in computing the income of a taxpayer for a taxation year, (a) any amount received by the taxpayer in the year as, on account or in lieu of payment of, or in satisfaction of, (ii) a retiring allowance, other than an amount received out of or under an employee benefit plan, (viii) a termination payment; 248. (1) “termination payment", for a taxation year, means an amount equal to the lesser of (a) the aggregate of all amounts each of which is an amount received in the year in respect of a termination of an office or employment, whether or not received pursuant to an order or judgment of a competent tribunal, other than (i) an amount required by any provision of this Act (other than subparagraph 56(1)(a)(viii)) to be included in computing the income of a taxpayer for a year, (ii) an amount in respect of which an election has been made under subsection 40(1) of the Income Tax Application Rules, 1971, and (iii) an amount received in the year as a consequence of the death of an employee, and (b) the amount by which 50% of the aggregate of all amounts each of which is the amount that may reasonably be considered to be the employee’s salary, wages and other remuneration from an office or employment for the 12 months preceding the date that is the earlier of (i) the date on which the office or employment was terminated, and (ii) the date on which an agreement, if any, in respect of the termination was entered into exceeds the amount determined under paragraph (a) for each previous year in respect of that termination whether the recipient is the officer or employee whose office or employment was terminated or a dependant, relation or legal representative of the officer or employee; B. ...
FCTD

Domenico Vespoli, Precision Mechanics Ltd, 80591 Canada Limited and Paradis Vespoli Ltée v. Her Majesty the Queen in Right of Canada, the Attorney General of Canada and the Honourable William Rompkey, in His Capacity as Minister of National Revenue, [1985] 2 CTC 11

The record does not contain any directions from the Court as contemplated in item 1 (4)(a) of Tariff A to vary that classification, therefore for the purpose of this taxation it will be considered as a class III action. ...
BCCA decision

Continental Aerial Services LTD v. Attorney General for Canada, [1985] 2 CTC 374, [1985] DTC 5534

He said this: I have considered Mr Caruso’s eidence concerning the famous artists he discussed, but I am not satisfied that his opinion should cause the "line” as spoken of by Pollock, CB, supra, to be shifted. ...
TCC

Clément Rivest v. Minister of National Revenue, [1985] 2 CTC 2031, 85 DTC 436

The following criteria should be considered: the profit and loss experience in past years, the taxpayer’s training, the taxpayer’s intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...
TCC

Kenneth J Byron v. Minister of National Revenue, [1985] 2 CTC 2139, 85 DTC 459

The respondent's position is the fact that the appellant’s farm business, although it had a reasonable expectation of profit, was nonetheless, a sideline business or was subordinate or auxiliary to the appellant’s full-time employment and could not be considered “‘a chief source of income". ...
TCC

Gilbert Brodeur v. Minister of National Revenue, [1985] 2 CTC 2201, 85 DTC 514

Mr Justice Décary in fact, concerning a payment of $20,000 said: It is my considered opinion that the decision of the Court of Appeal as to the nature of the $20,000 for purposes of civil relations between the parties cannot be ignored in establishing the tax nature of this amount. ...
FCTD

Consumers Glass Company Limited v. Minister of National Revenue, Deputy Minister of National Revenue for Customs and Excise, Andrew a Bradley and George Schoenhofer, [1985] 1 CTC 15

If the United States exporters do not provide the information requested by the Department that it considered necessary to carry out the review or if the information provided is insufficient, the Department has taken the position that the normal value would be determined or established in accordance with section 11 of the Act. ...
TCC

Charles a Beghin v. Minister of National Revenue, [1985] 1 CTC 2034, 85 DTC 48

Even if holding the five acres could be considered as a motivating factor in the appellant’s acquisition of his one-third undivided interest in the land, a proposition which in my opinion is not supported by the facts, it would at best be a contingency plan and speculative in nature because the five acres were to be used by the appellant only if circumstances made it necessary for him to do so. ...

Pages