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Results 2871 - 2880 of 14741 for considered
TCC
166020 Canada Inc. v. M.N.R., 2014 TCC 220
She agrees that the intention of the parties is quite clear that they considered the relationship to be that of independent contractors, not employer/employee. ... As noted in Royal Winnipeg Ballet at para. 64, the relevant factors must be considered “in the light of” the parties’ intent. ... [55] This is not a telling factor but to the extent that it must be considered, it would contra‑indicate an employer/employee relationship. ...
FCTD
Buffalo Point Cottagers Association Inc. v. Buffalo Point First Nation, 2014 FC 1173
The Cottagers considered the TRL to be vitally important because it would provide a measure of representation in the operation of the tax regime. [37] The Cottagers were misinformed that a TRL is mandatory under the Act. ... That is, on the basis of conflicting evidence received, findings of fact would be made, the facts would be considered against the law to be applied, and a reasoned decision would be provided. ... [Emphasis added] [49] There is no doubt that the Commission considered the letter because it is contained in documentation supplied by the Commission in the present Application (Certified Copy of Tribunal Record, p. 107b- 110). ...
FCTD
Canada (Human Rights Commission) v. Canada (Attorney General), 2015 FC 398
The Tribunal decision is structured to reflect those questions and to answer them. [13] The Tribunal considered three issues. First, it considered whether the complaint was a challenge to legislation. ... At page 5, the speaking notes considered the revision of section 12(1)(b), which related to registration. ...
FCTD
Manfoumbimouity v. Canada (Attorney General), 2016 FC 988
His complaint stated that certain events had not been considered by the Provost Marshal. [28] The Complaints Commission reviewed the Provost Marshal’s findings in a 19-page document. ... Therefore, the only evidence that can be germane to the judicial review is evidence that had been considered by the administrative tribunal. ... Standard of review [48] The reasonableness standard applies to review of a Commission’s decision to refuse to proceed with a complaint because it is considered trivial, frivolous, vexatious or made in bad faith. ...
FCA
Penner International Inc. v. Canada, 2002 FCA 453
For example, if a person acquires wine in Canada, takes it to the United States and consumes it there, it seems to me that the wine must be considered to be exported whether the person is a resident or non-resident and even though the person is not entitled to a GST rebate on the wine. [17] Under subparagraph 252(1)(c)(ii), the diesel fuel used in the vehicle in which it has been transported is considered to be exported. I find it difficult to think that Parliament considered the term "exported" in subsection 68.1(1) to mean anything different. ... By analogy, the mere consumption of fuel is not sufficient to be considered part of the export process, let alone an "export". ...
FCTD
Robinson v. Canada (National Revenue), 2018 FC 825
Robinson were considered and the reasons provided were intelligible, justified, and transparent. ... ANALYSIS [87] Throughout this analysis it is important to remember that the Decision Maker is presumed to have considered all the evidence before them including Mr. ... Likewise, knowingly allowing a balance to exist is a factor to be considered under paragraph 33(b). [124] The evidence in the record shows that Mr. ...
FCTD
9027-4218 Québec Inc. v. Canada (National Revenue), 2019 FC 785
Barry had verbally confirmed that the compensation from the MTQ would be considered to be a capital gain in the hands of the applicants. ... Conclusion [90] Furthermore, the applicants had expectations that their adjustment request would be considered as was confirmed by Mr. ... The Minister followed the expected process and considered the adjustment request of February 4, 2015. ...
FCA
Oceanex Inc. v. Canada (Transport), 2019 FCA 250
It first considered who, as between the Minister and Marine Atlantic, made the decision to implement the 2016/17 rates, and concluded that it was Marine Atlantic. ... In deciding to grant Oceanex public interest standing, the Federal Court considered the relevant factors and gave particular emphasis to the concern that rate decisions raising serious justiciable issues might otherwise be immune from review. ... L.R. (5th) 401, leave to appeal refused, [2014] 2 S.C.R. vii. [69] In Ferroequus and Moffat, this Court considered the role of the NTP in the Canadian Transportation Agency’s exercise of its powers under the CTA. ...
FCTD
Gary C. Graves and Mary J. Graves v. Her Majesty the Queen, [1990] 1 CTC 357
Reasons for Judgment be considered as expenses of a partnership and should be claimed by each partner on a 50% basis” From that decision the plaintiffs appeal. ... The Graves had no sign and no separate business telephone, but these are only some of the factors to be considered. ... Earlier reference has been made to cases, dealing with similar claims by Amway dealers for expenses, considered by the Tax Court since 1983. ...
TCC
Aqua-Gem Investments Ltd. v. Minister of National Revenue, [1986] 1 CTC 2528, 86 DTC 1392
Generally speaking, interest is considered as income* from property. As a general consideration, it might be useful to quote an extract from the article of Vern Krishna referred to above in paragraph 5.02(15). ... The appellant argued that the purpose of the investments was profit, citing the time taken to manage them, and that if considered separately, the investment activity constituted an active business. ... However, to be considered as an integral part of the business, the two taxpayers’ activities, business and investment, must be interdependent. ...