Search - considered
Results 13871 - 13880 of 14785 for considered
FCTD
Windrim v. The Queen, 91 DTC 5221, [1991] 1 CTC 271 (FCTD)
For the purposes of this Act, (a) a taxpayer's taxable capital gain for a taxation year from the disposition of any property is /2 of his capital gain for the year from the disposition of that property; and 54, In this subdivision, (g) “principal residence" of a taxpayer for a taxation year means a housing unit, a leasehold interest therein,... owned,... in the year by the taxpayer, if the housing unit was, (i) ordinarily inhabited in the year by the taxpayer... except that, subject to section 54.1, in no case shall any such housing unit, interest or share, as the case may be, be considered to be a taxpayer's principal residence for a year (iii) unless it has been designated by him in prescribed form and manner to be his principal residence for that year, and no other such housing unit... has been so designated for that year by him... and for the purposes of this paragraph the” principal residence” of a taxpayer for a taxation year shall be deemed to include, except where the property consists of a share of the capital stock of a co-operative housing corporation, the land subjacent to the housing unit and such portion of any immediately contiguous land as may reasonably be regarded as contributing to the taxpayer's use and enjoyment of the housing unit as a residence, except that where the total area of the subjacent land and of that portion exceeds 1/2 hectare, the excess shall be deemed not to have contributed to the individual's use and enjoyment of the housing unit as a residence unless the taxpayer establishes that it was necessary to such use and enjoyment; [Emphasis added.] ...
FCTD
Graham v. The Queen, 83 DTC 5399, [1983] CTC 370 (FCTD), aff'd 85 DTC 5256, [1985] 1 CTC 380 (FCA)
To reach that standard he considered it expedient to continue in his employment at Ontario Hydro, having reached the capacity of 40 sows on the home place expropriated in 1982 and to achieve the objective of 64 sows on the new farm. ...
TCC
DeWitt v. MNR, 90 DTC 1027, [1990] 1 CTC 2098 (TCC)
L.R. (2d), 165 (Q.B.) considered these provisions and held that the Registrar's certificate of continuance was conclusive proof as to a company's continued status under the A.B.C.A. ...
TCC
Leung v. MNR, 91 DTC 1020, [1991] 2 CTC 2268 (TCC), rev'd 93 DTC 5467 (FCTD)
The nature of an assessment was considered by Thorson, P. in Pure Spring Co. v. ...
FCA
The Queen v. Coopers & Lybrand Ltd., Trustee of Hawboldt Hydraulics (Canada) Inc., 94 DTC 6541, [1994] 2 CTC 336 (FCA)
I believe, that whatever may need to be done in the future to meet changing world conditions, parliament should adopt the measures we are now proposing to help our manufacturing and processing industries to meet and match the increasingly intense competition they face from foreign companies both in our own home market and in markets abroad..... the measures now being considered by the House provide a concrete and positive means of helping to overcome the critical problems confronting Canada’s manufacturing and processing industries over the medium and longer term. ...
TCC
Sun Life Assurance Co. of Canada v. R., 97 DTC 422, [1997] 3 C.T.C. 2593 (TCC)
Accordingly, they are considered to be a part of the project and should be capitalized. ...
FCTD
Pollock v. The Queen, 90 DTC 6142, [1990] 1 CTC 196 (FCTD), aff'd 94 DTC 6050 (FCA)
In computing his capital gain, he deducted from the proceeds of disposition of the shares what he considered to be the adjusted cost base to him. ...
TCC
Green v. The Queen, 2016 DTC 1018 [at 2629], 2016 TCC 10
However, in my opinion, only one of those provisions, subparagraph 53(2)(c)(i), offers contextual guidance for the specific interpretive question arising in this case. [41] Subparagraph 53(2)(c)(i) of the Act reduces the adjusted cost base of a partnership interest by the taxpayer’s share of any loss of the partnership from any source for that fiscal period, except to the extent that all or a portion of such a loss may reasonably be considered to have been included in the taxpayer’s limited partnership loss in respect of the partnership for the taxpayer’s taxation year in which that fiscal period ended, [42] As the Appellants’ counsel points out, if a limited partnership loss did not also retain its character as a business loss, there would be no need to include the portion of subparagraph 53(2)(c)(i) reproduced above. ...
FCA
Canada v. Scheuer, 2016 DTC 5011 [at 6551], 2016 FCA 7
Had the Judge considered the legislative regime at this stage of the analysis, he would have concluded that no tort liability can, or should, be imposed upon the Minister for simply issuing a tax shelter identification number because, in so acting, the Minister exercises no discretion. ...
TCC
Marra v. The Queen, 2016 DTC 1028 [at 2696], 2016 TCC 24
Lefebvre [7] where Mesbur J. of the Ontario Superior Court of Justice considered section 108 of the Canada Business Corporation Act, that resignation of a director is effective at the time a written resignation is sent to a corporation. ...