Search - considered
Results 3841 - 3850 of 14745 for considered
SCC
Eurig Estate (Re), [1998] 2 SCR 565
He concluded that even if the fees were considered to be taxes, they were ingredients of a regulatory scheme not covered by ss. 53 and 54. ... York Region Board of Education, [1996] 2 S.C.R. 929, at p. 988. 15 Whether a levy is a tax or a fee was considered in Lawson, supra. ... This nexus was also considered relevant to determining the nature of a municipal charge in Allard Contractors, supra. ...
TCC
Frank Beban Logging Ltd. v. R., 98 DTC 1393, [1998] 2 C.T.C. 2493 (TCC)
He considered “going public” by contacting the press and electronic media to explain the unfair treatment of FBL. ... In an agarian society, land is considered to be the source of income. ... Cameron J. considered the cases such as J. Gliksten and Son, Limited v. ...
TCC
Superior Plus Corp. v. The Queen, 2015 DTC 1124 [at at 765], 2015 TCC 132, aff'd 2015 FCA 241
Instead, the subsequent amendment must be considered along with all other relevant materials to ascertain the object, spirit and purpose of the provision. ... Whether officials of the Department of Finance internally considered a retroactive amendment is irrelevant. ... Decision: As stated in Gwartz, a subsequent amendment may be considered in ascertaining the object, spirit and purpose of the provisions at issue. ...
FCA
Water's Edge Village Estates (Phase II) Ltd. v. Canada, 2002 DTC 7172, 2002 FCA 291
It was considered to be obsolete in North America. [5] On December 13, 1991, a British Columbia promoter by the name of Hutton and a company through which he conducted his activities purchased, on an interim basis, a 98% interest in Klink for $51,500. ... That the alleged partnership must be considered in the totality of the circumstances prevents the mechanical application of a checklist or a test with more precisely defined parameters. ... If so, can the transactions reasonably be considered to have been undertaken primarily for a purpose other than to obtain a tax benefit? ...
TCC
101139810 Saskatchewan Ltd. v. The Queen, 2017 TCC 3
[22] The appellants are of the view that in determining whether there was a significant reduction in the capital gain or not, the transactions must be considered in their entirety and not in isolation. ... Double taxation can only be considered to exist where it is equitable and/or the language of the taxing Act is clear and unequivocal. [72] At paragraph 30 of the judgment, Justice Hamlyn stated: There is a valid concern to prevent the same amount from being taxed twice, whether in the hands of a single taxpayer (See Perrault v. ... The Act creates no legal fiction which would have the effect of nullifying this distinction or by virtue of which the property of a corporation would be considered that of the shareholders. ...
TCC
Grove Acceptance Ltd. v. The Queen, docket 2000-4726(IT)G
(an) important factor to be considered is the proportion of the amount of space rented in relation to the total area of the building. ... " are to be considered having regard to two approaches, one quantitative and the other qualitative. ... Under the qualitative approach, the owner's main purpose in using the property in the taxation year must be considered; hence, the words following "but for greater certainty... ...
TCC
1207192 Ontario Limited v. The Queen, 2011 TCC 383
Cross because he considered that the guarantees he had given for SSI exposed him to a high risk of significant future liability ... The alternative approaches that we have considered are no more advantageous than this structure in meeting the [client’s] objectives ... All that can be said is that none of the undisclosed alternatives that were considered would have been more effective in their result or more advantageous to the client ...
TCC
The Ottawa Hospital Corporation v. The Queen, 2010 TCC 53
The line between those bodies that will be considered Crown agents at common law and those that will not is anything but precise. ... Miller J. considered a situation involving the appointment of a supervisor under the Education Act, R.S.O. 1990, c. ... No. 564, considered the general agency principle that the principal, and not the agent, should bring the action. ...
TCC
Yudelson v. The Queen, 2009 TCC 80
It is considered objectionable to allow the $15,000 DB pension to be commuted to an RRSP that could permit a greater annuity amount to be paid. ... The transfer for the purchase of the annuity cannot therefore be considered an amount received by the Appellant from the RPP. ... At any rate, subparagraph 8503(2)(a)(iii) allows indexation benefits to be considered LRBs in the absence of both periodicity and equality of payments ...
TCC
Société de Transport de Laval v. The Queen, 2008 TCC 14
The Minister determined that amount on the basis of the Appellant's current expenses as detailed in Exhibit I‑6 (which current expenses he considered as established). ... The Minister determined that amount on the basis of the Appellant's current expenses as detailed in Exhibit I‑4 (which current expenses he considered as established). ... The difficulty here lies in the fact that the user might also be considered a "recipient" of the supply of transportation. ...