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Results 4391 - 4400 of 14766 for considered
T Rev B decision
Richard W Jarvis v. Minister of National Revenue, [1981] CTC 2153, 81 DTC 89
The second issue about which the appellant felt very strongly was that his spouse had contributed so much to the success of his business that she deserved to be considered as half-owner of his shares. ...
T Rev B decision
Brenda a Robichaud v. Minister of National Revenue, [1981] CTC 2173, 81 DTC 185
However, as most of the expenses were for commodities which were used after the marriage (suits, food, cablevision, etc), in the Board’s opinion, those expenses must be considered as expenses made to support the appellant’s spouse after the marriage. ...
T Rev B decision
Edward Libera v. Minister of National Revenue, [1981] CTC 2298, 81 DTC 276
The limitation imposed by section 67 of the Income Tax Act was considered in Gabco Limited v MNR, [1968] CTC 313; 68 DTC 5210 at 323 [5216] where Cattanach, J stated: It is not a question of the Minister or this Court substituting its judgment for what is a reasonable amount to pay, but rather a case of the Minister or the Court coming to the conclusion that no reasonable businessman would have contracted to pay such an amount having only the business consideration of the appellant in mind. ...
T Rev B decision
Martin a Bitz v. Minister of National Revenue, [1981] CTC 2426, 81 DTC 382
The appellant considered the transaction to have been on capital account, the respondent assessed it on revenue account. ...
T Rev B decision
Norman B Boychuk v. Minister of National Revenue, [1981] CTC 2662, 81 DTC 613
The issue here is simply whether the payment received by the appellant can be considered as damages for wrongful dismissal. ...
T Rev B decision
Fernand Larose v. Minister of National Revenue, [1981] CTC 3035, 81 DTC 957
The adjourned hearing will be rescheduled by the Board to provide the parties with an opportunity to bring forward further matters considered by them to be relevant to the appeal. ...
FCTD
Harold J Sachs v. Her Majesty the Queen, [1980] CTC 39, 80 DTC 6023
The trust deed at Article VIII provides as follows: ARTICLE VIII: PAYMENT OF INCOME AND CAPITAL The Trustee shall invest and keep invested the Trust Estate until the first day of December, 1991 (hereinafter referred to as ‘distribution date’) and may, from time to time, pay none, some or all of the net income derived therefrom or none, some or all of the capital thereof to or for the benefit of one, some or all of the children of the Settlor as the Trustee shall, in his absolute and uncontrolled discretion, determine; any income not so paid or applied in any calendar year to be added to form part of the Trust Estate; on the distribution date the Trust Estate shall be divided into as many equal shares as there shall be children of the Settlor then alive; any child of the Settlor who shall not be then alive, but who shall have children him or her surviving, shall be considered alive for the purposes of such distribution; the Trustee shall keep the share from each such child invested and shall pay income and capital to such child upon such terms and in such manner as hereinfore provided until such child shall attain the age of 25 years, whereupon 3 of his or her share shall be paid to him or her for his or her own use absolutely; the remainder of such share shall be kept invested as aforesaid and the income and capital shall be paid as aforesaid until such child shall attain the age of 30 years whereupon the amount of such share remaining shall be paid to him or her for his or her own use absolutely; provided, however, that in the event that any such child shall die prior to the distribution date or, surviving the distribution date shall die prior to attaining the age of 25 years or, shall die prior to attaining the age of 30 years, leaving children him or her surviving, then the interest of such child in his or her share shall be subject to the defeasance and the share of such child or the amount thereof remaining shall be held in trust for the children of such deceased child alive at the date of such deceased child’s death in equal shares per stirpes, upon such terms and in such manner as herein provided; in the further event that such deceased child shall die in such manner as aforesaid, leaving no children him or her surviving, then the share of such deceased child or the amount thereof remaining shall be subject to defeasance and shall be held in trust for the brothers and sisters of such deceased child alive at the date of death of such deceased child in such manner as herein provided; in the further event that there shall be no children of the Settlor alive at the distribution date or all of them shall die prior to attaining the age of 25 years or, if one or some of them shall have attained the age of 25 years but shall die prior to attaining the age of 30 years leaving no children them Surviving, to pay over the Trust Estate to or for the benefit of MERIDA PHYLLIS SACHS for her own use absolutely. ...
T Rev B decision
C W Moncrieff v. Minister of National Revenue, [1980] CTC 2039, 80 DTC 1035
We therefore request that the above circumstances be taken into consideration in Mr Moncrieff’s appeal and that of the annuity payments reported on the T4RSP issued by NALACO, an amount proportional to the pension plan proceeds/total annuity premium be considered eligible for the pension plan deduction in 1977 and future years. ...
T Rev B decision
Thomas G Smith v. Minister of National Revenue, [1980] CTC 2186, 80 DTC 1166
The respondent also relied upon paragraph (b) of subsection (1) of section 146 which reads as follows: (1) In this section, (b) “benefit” includes any amount received out of or under a retirement savings plan otherwise than as a premium and without restricting the generality of the foregoing includes any amount paid to an annuitant under the plan (i) in accordance with the terms of the plan, (ii) resulting from an amendment to or modification of the plan, or (iii) resulting from the termination of the plan; Counsel for the respondent asserted that the monies received by the appellant in 1976, as a result of the termination of the plan, were considered a benefit and consequently income pursuant to subsection (8) of section 146. ...
T Rev B decision
Roselawn Investments Limited v. Minister of National Revenue, [1980] CTC 2316, 80 DTC 1271
Common to both statutory provisions considered in the Taylor case and to the present section 152 is a restriction on the power of the Minister to reassess after the normal period to cases where the taxpayer (or person filing the return) has made a misrepresentation or committed fraud. ...