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TCC

Bibby v. The Queen, 2009 TCC 588

The Minister of National Revenue has considered the reasons set out in your objection and all the relevant facts. ...
TCC

F. Ménard inc. v. M.N.R., 2009 TCC 208

  [70]          In this case, there were not very many facts to be considered; clearly, there would have needed to be more facts gathered from the investigation. ...
TCC

Burstein v. The Queen, 2009 TCC 103

In this view, “the day of … original assessment” referred to in Section 46(4) was in the present case May 28, 1953, and it remains to be considered whether the re-assessment under appeal was made within four years from that day.  ...
TCC

Homer v. The Queen, 2009 TCC 219

For paragraph 251(1)(b) to apply, the transferor has to be either the trust created by the will or the estate, a trust and an estate being considered one and the same by virtue of subsection 104(1) of the Act. ...
TCC

Comparelli v. The Queen, 2009 TCC 57

The Company does not have an established history of actual operations of its current business upon which an investor can base an investment decision, and the likelihood of success of the Company must be considered in view of all of the risks, expenses and delays inherent in establishing, operating and expanding a new business, including, but not limited to, unforeseen expenses, complications and delays, the uncertainty of market acceptance of new services, intense competition from larger, more established competitors and other factors.   ...
TCC

VidAmour v. The Queen, 2009 TCC 414 (Informal Procedure)

Further, the longevity of the relationship should be considered. The longer the relationship has endured, the chances of finding a proprietary interest is more compelling ...
TCC

The City of Brandon v. The Queen, 2009 TCC 369

  [48]          It is accepted that, while not determinative, the views of the administrator have some weight and may be considered. [24] It is also accepted that, while not determinative, Technical Notes are entitled to consideration. [25]   [49]          In the 2009 Canada Revenue Agency (the “CRA”) publication, GST/HST Information for Municipalities, it is stated:   A supply of a service of installing, repairing, maintaining or interrupting the operation of a water distribution, sewerage, or drainage system, is not subject to GST/HST if the supply is made by a municipality or by an organization designated as a municipality for this purpose.   ...
TCC

Pate v. The Queen, 2007 TCC 452

Maarten, Netherlands Antilles part of the address was used because he had once visited the Netherlands Antilles with his wife, and they had considered buying a timeshare unit there. ...
TCC

Métal Sartigan Inc. c. La Reine, 2007 TCC 213

Given the type of property considered, neither the APCHQ nor the ACQ are willing to issue a certificate of new guarantee to the owner due to the risk inherent to the product offered. ...
TCC

Cormier v. The Queen, 2007 TCC 88

Prior to the legislative amendments of 1997, child support was considered a source of income and had to be included in the receiving taxpayer's income. ...

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