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Results 4011 - 4020 of 14746 for considered
TCC
Prue v. M.N.R., 2011 TCC 9
Prue stated she considered that a change in her duties – in January, 2009 – had transformed her into an employee. ... Prue considered the unilateral decision by Strauss to pay her twice a month by direct deposit was another example of control ... With respect to the conduct of Prue during the relevant period, it is evident she considered herself to be an independent contractor. ...
TCC
Lockie v. The Queen, 2010 TCC 142 (Informal Procedure)
The tax advantage which is received from gifts is not normally considered a “benefit” within this definition, for to do so would render the charitable donations deductions unavailable to many donors ... So the other piece that I considered was what price would be paid by IKC or the charities that benefited from these toothbrushes and gel pens. ... Donation program should not be considered to be an investment market. ...
TCC
Dewdney Transport Group Ltd. v. M.N.R., 2009 TCC 569
(from paragraph 71 of the lead judgment in Wolf), if it is established that the terms of the contract, considered in the appropriate factual context, do not reflect the legal relationship that the parties profess to have intended, then their stated intention will be disregarded ... In the case of Vida Wellness he considered the work situation of six massage therapists whom the Minister considered to have been engaged in both insurable and pensionable employment notwithstanding each worker had entered into a written agreement in which it was stipulated they were independent contractors. ... [25] Miller, J. considered the element of control to be consistent with the relationship the parties had agreed to and while he put little emphasis on the ownership of tools, found that factor was no more consistent with employment than with the status of independent contractor. ...
TCC
Sheppard v. M.N.R., 2009 TCC 97
He considered the pay arrangement was an interim measure until TWDS – through its financially secure members- assumed responsibility for the ongoing operation of TLC. ... He taught Hall’s son at the Vancouver Waldorf School and considered Hall had hired him because he could adapt that educational philosophy to accommodate the Davis Method. ... From his perspective, Sheppard considered his role was that of a qualified teacher responsible for the educational core of the fledgling entity. ...
TCC
Loewen v. The Queen, 2007 TCC 703
During the meeting of February 8, 2000, we re-considered what Mr. Phil McDonnell had suggested which were as follows: ■ Was it run as a company? ... Jang considered the question of contingency and decided that the notes were not contingent. ... To permit the amendments would be to permit all relevant provisions bearing on the appellants’ right to the claimed deductions to be considered at trial. ...
TCC
3105822 Canada Inc. v. M.N.R., 2008 TCC 305
It considered certain employees independent contractors. An insurability ruling changed their status to that of employees, hence the 2002 and 2003 assessment. ... The Amro brothers considered these agents independent contractors. According to Mr. ... Rousseau stated that just about everyone he considered to be an employee had said the same thing. ...
TCC
Cheung v. The Queen, 2005 TCC 83 (Informal Procedure)
He stated his family did not spend much money on clothing and considered an annual expenditure of $1,500 was reasonable rather than the amount of $3,118.83 assumed by the Minister. ... The Queen, 2001 DTC 5459, the Federal Court of Appeal considered the appeal of the taxpayer who had been reassessed by the Minister on the basis of a net worth assessment. ... An amount payable- but not paid- cannot be considered as a cash flow requirement. ...
TCC
Quantetics Corp. v. The Queen, docket 91-1411-IT-G
Consequently, the appeal for the 1985 taxation year will be dealt with in accordance with the law as it applied on or before May 23, 1985, and the appeals for the 1986 and 1987 taxation years will be considered in light of the law as it applied after that date. ... Before a bonus can be considered as an integral part of salary and a deductible expense, it must, in my view, meet certain criteria. ... Judge Rip also considered that the bonus could be a contingent liability pursuant to paragraph 18(1)(e) of the Act. [60] Similarly, counsel for the respondent submits, in the present case there is no evidence of any legal obligation on the part of the appellant to pay a bonus of $1,400,000 to its principal shareholder. ...
TCC
Superior Plus Corp. v. The Queen, 2016 TCC 217
I have highlighted examples in the context of Ontario civil litigation where follow‑up questions that could have been posed at the original examination were considered not to be “ proper ”. ... Jina whether the Respondent has knowledge of whether Finance considered making a retroactive amendment, and if the Respondent has no such knowledge, to make inquiries to determine the answer, and to inquire of Finance whether it considered such a step. [59] [75] The Respondent refuses the question on the basis that this is not proper follow-up and that the question could have been asked at the September Discovery. In the alternative, the Respondent submits that internal Finance communications or analyses neither arising in the context of the audit nor considered by officials involved in the audit are not relevant. ...
TCC
Spruce Credit Union v. The Queen, 2014 TCC 42
Appellant’s counsel says this “already provided discount” is a relevant factor to be considered. ... Words found in legislation are not generally considered redundant. As stated by the Supreme Court in Hills v. ... There were no particular inefficiencies, delays, inappropriate conduct or settlement offers to be considered each of which might have moved this further up the range ...