Search - considered

.), Associate Chief Justice Jerome stated at page 366 (D.T.C. 5619): In Satellite Earth, MacKay J. reviewed the factors to be considered by a court on a subsection 225.2(8) review of a jeopardy collection order. ...

McMechan argued that such evidence should not be considered because it was precluded by section 241 of the Tax Act, I do not read section 241 that way. ...

To formulate a decision then, the overall evidence must be considered taking into account those of the tests which may be applicable and giving to all the evidence the weight which the circumstances may dictate. ...

In particular, we have in mind the fact that the two organizations that negotiated the payment, and that therefore knew why it was made, both considered that the amount counted as income, that it was paid for and on behalf of the employer and was distributed in proportion to the days worked, that the Commission's decision mentioned wage discrimination (appeal book, page 36) and that in this case there was no evidence of moral injury. [16]      The appeal will be dismissed with costs. ...

.), at pp. 316-317]:   The principles applicable to a plea of res judicata are not in doubt and have been considered in detail in the judgment of the Court of Appeal. ...

Clearly, therefore, the breakdown was a considered element in the agreement between a knowledgeable vendor and purchaser operating at arm's length. ...

Crampton" Chief Justice FEDERAL COURT SOLICITORS OF RECORD   Docket: T-283-13     STYLE OF CAUSE: MINISTER OF NATIONAL REVENUE V KPMG LLP   MOTION IN WRITING CONSIDERED AT OTTAWA, ONTARIO PURSUANT TO RULE 369 OF THE FEDERAL COURTS RULES ORDER AND REASONS: CRAMPTON C.J.   ...

At my invitation during the conference call to make representations in the present matter, counsel for the Appellants did not attempt to distinguish the issue in the present cases from that considered by the Federal Court of Appeal in the Trengrove case mentioned earlier. [6] Judge Rip had decided in the Trengrove case that the new Housing Rebates, on account of FST and GST, which had been transferred to the builders formed part of the consideration that was subject to GST. [7] I am of the opinion that the decision of the Federal Court of Appeal is applicable to the present appeals, the issue being the same in both sets of cases. [8] I therefore come to the conclusion that the FST and GST new Housing Rebates which were assigned/transferred to the Appellants herein formed part of the value of consideration for the supply of the new houses. [9] Accordingly, the appeals from the assessments are dismissed with costs. ...

He later realized his mistake and concluded that he could obtain additional input tax credits if he was considered the contractor for part of the invoices. ...

I have considered the submissions made and the evidence and I cannot find any valid legal reason to conclude that these expenses are somehow deductible in 1992. ...