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TCC

Campbell v. The Queen, 2010 TCC 67 (Informal Procedure)

All things considered, residence implies a certain constancy, a certain regularity or else a certain permanence according to a person's usual lifestyle in relation to a given place and is to be distinguished from what might be called visits or stays for specific purposes or of a sporadic nature. ... As a result neither parent could be considered as the parent who primarily fulfilled this responsibility ... It seems to me that neither one of the two parents would be considered to be the parent who primarily fulfilled this responsibility ...
TCC

Perry v. M.N.R., 2010 TCC 266

Perry stated that when she performed those housekeeping duties, she had not recorded her time since she had considered that work as part of her overall responsibility for which she received a monthly salary. ... After having considered all the evidence, the decision of the Minister is still reasonable. Certain facts were considered by the Minister and a subsequent analysis was undertaken of the relevant indicia as required by the legislation. ...
TCC

Denisov v. The Queen, 2010 TCC 101

An individual who is ordinarily resident in Canada is considered to be factually resident in Canada. ... Reeder, 75 DTC 5160 (F.C.T.D.), referred to by the appellant, the court listed some factors considered to be material in determining the question of fiscal residence, at page 5163:  ... ... In the event that the appellant, as a result of the application of Article 4 of the tax treaty, is considered to have been a resident of Russia, he will be deemed not to have been resident of Canada for the purposes of the Act ...
TCC

Morrison v. The Queen, 2010 TCC 429 (Informal Procedure)

This payment shall be considered to be an advance from the Purchaser to the Corporation on the terms and conditions of the Loan Documentation.   ... In this situation it seems to me that the amounts paid or payable as reflected in these entries that adjusted the balance payable at May 31, 1998 to reflect the balance payable at December 31, 1998 should be considered to be paid or payable at the same time and therefore the additional entries simply reduce the amount payable to Susan Morrison by $3,781. ... It seems to me that perhaps these could have been considered to be adjustments to the purchase price but this was not argued by the Appellants and there was no evidence of how the gain on the sale of the shares was reported. ...
TCC

3087-8847 Quebec Inc. v. The Queen, 2007 TCC 302

Thomas Lavin said that he considered that amount to be a share capital investment in the company. ... Dunn considered it as a “building loan” made by the appellant to Ms. Farr in the appellant’s 1995 fiscal year. ... Dunn was always considered as share capital on the in-house balance sheets. ...
TCC

Dimaria v. The Queen, 2008 TCC 114

We understand, however, that under the previous program when an unlimited number of dependants were considered for a scholarship, less than 100 dependants actually received an award. ... In any event, it cannot be considered that the Appellant received anything from Dow other than his usual compensation. ... There are a variety of factors which could be applicable and might be considered on a case by case basis:   1.                  ...
TCC

Dubé c. La Reine, 2007 TCC 393

In Sero and Frazer, Sharlow J.A. also considered certain criticisms regarding Recalma, but saw in these none that could change her finding that the investment income was not situated on a reserve. ... the extent to which the investment income may be considered as being derived from economic mainstream activity ...   [40]     In the present case, counsel for the appellant addressed all of the factors considered by Judge Hamlyn at first instance in Recalma. ...
TCC

McMillan Properties Inc. v. M.N.R., 2005 TCC 654

Kelebay stated he considered his service to MPI to extend beyond the normal range expected from a typical manager of that type of rental property. ... By following that approach, a corporation director would be considered an employee only if the person holding that position was entitled to a fixed or ascertainable stipend or remuneration by virtue of the fact he or she occupied that position. ... The Queen, 94 DTC 6193, the Federal Court of Appeal considered the case of a taxpayer who received options while a director of a company. ...
TCC

Ville de Gatineau (Communauté Urbaine de l'Outaouais) v. The Queen, 2005 TCC 358

The CUO subsequently considered processing the sludge, and the granulation plant went into operation in 1992. ... The water purification service must therefore be considered separately, just as the collection of recyclable materials (exempt supply) was considered in the context of the recyclable materials sorting operation (which in itself constitutes a commercial activity) in Montréal (City) v. ... The Federal Court of Appeal considered how close an expense had to be to the commercial activity itself. ...
TCC

Capri Interiors Ltd. v. M.N.R., 2004 TCC 23

I sensed that those who did not very much considered themselves as independent contractors. ... They considered that they worked for themselves and were proud of that independence. ... Clearly, most of them considered themselves to be in business for themselves, as did Capri. ...

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