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TCC
DAC Investment Holdings Inc. v. The King, 2024 TCC 63
This will be evident once the function that each of the definitions plays in the scheme of the Act is considered. [72] Numerous provisions of the Act distinguish between a public corporation, a CCPC and a private corporation. ... Such corporations will then not be considered resident in Canada unless their central management and control are located in Canada. ... For example, the Appellant was no longer deemed to be resident in Canada, no longer considered to be a Canadian corporation and no longer considered to be a CCPC. [231] The fact that it remained a resident in Canada did not frustrate the object, spirit and purpose of subsection 250(5.1). ...
EC decision
Hudson’s Bay Company v. Minister of National Revenue, [1947] CTC 86
The various Income Tax Acts considered in the aforesaid cases, apart from that of Minister of National Revenue v. ... On the other hand, I do not believe that these expenses and costs can be considered as being a capital outlay or loss. ... I do not believe that these costs and expenses can be considered as a capital outlay. ...
TCC
Canadian Forest Products Ltd. v. The Queen, 2004 DTC 2869, 2004 TCC 405
He considered the unpresented cheques to be a liability to Canfor for accounting purposes and they are shown as such in the financial statements. ... It is at this time that the bank has made available to the borrower the use of the funds. [9] [54] The Courts have considered the application of the Part I.3 tax in a number of cases albeit none directly on point with the issue here today. ... In common law jurisdictions delivery of a cheque constitutes payment at that time. [90] The writing of a cheque on a bank account is considered to constitute a draw upon that account where that cheque represents payment. ...
TCC
Ridge Run Developments Inc. v. The Queen, 2007 DTC 734, 2007 TCC 68
Poulton considered him to be the "whole company" in all the decisions with respect to Oakamp Developments. ... That is when it was considered that the loan was forgiven. At that point in time there was no more loss available to be reduced. ... If he was told that it need not be reported then he may have avoided being considered to be negligent or careless. ...
TCC
President's Choice Bank v. The Queen, 2009 TCC 170
Each supply must be considered as an independent supply for tax purposes, the single consideration being apportioned among the separate supplies as appropriate. ... One factor to be considered is whether or not the alleged separate supply can be realistically omitted from the overall supply. ... These services in themselves are not otherwise considered to be financial services under paragraphs (a) to (m) of the definition in subsection 123(1) of the ETA. ...
TCC
Great-West Life Assurance Company v. The Queen, 2015 TCC 225
A limit on the amount paid in respect of a particular claim to what is considered “reasonable and customary”. ... However, the maintenance of DIN price and formulary files and DUR files for use in the adjudication process cannot be considered to define the essential character of the supply provided by Emergis to Great-West. ... It is worth noting that this regulation will affect only services that would otherwise be considered to be financial services under paragraphs (a) to (m) of the definition under subsection 123(1). ...
FCTD
Oro Del Norte S.A. v. The Queen, 93 DTC 5217, [1993] 1 CTC 245 (FCTD)
The jurisprudence is helpful in suggesting factors which might by analogy be considered in determining whether particular mine workings constitute a mine separate from an existing mine that has already come into production in reasonable commercial quantities. ... Coal resources of immediate interest, as contrasted with those of future interest, are seams of coal that because of thickness, depth, quality and location are considered to be of immediate interest for exploitation. ... Within that industry development expenses would be committed only when a reserve has been established that is considered to be likely to produce a Satisfactory profit from production as a result of planned investment in a specific project. ...
SCC
Rogers Communications Inc. v. Society of Composers, Authors and Music Publishers of Canada, 2012 SCC 35, [2012] 2 SCR 283
The view that we can extricate a legal question from this context of complex, interlocking facts and policies considered by the Board in setting a tariff, is unrealistic. ... Accordingly, finding SOCAN’s claim to be valid in law, the Board proceeded to establish the tariffs it considered appropriate ... Alliance Pipeline Ltd., [2011] 1 S.C.R. 160, considered — and rejected — concerns over the possibility of multiple interpretations flowing from deference. ...
TCC
Koskocan v. The Queen, 2016 TCC 277
In the alternative, if he were to be considered a de facto director of 9056, Mr. ... Under these circumstances, this should not be considered an example of an action taken by a director. ... If the ARQ made such an assessment in respect of Mehmet Koskocan, it was because it considered him a de facto director. ...
TCC
Drouin v. The Queen, 2012 TCC 94
We are now at the stage of determining the admissibility of the proposed testimony and the content of Gagnon's report is not to be considered at this stage of the proceedings. ... The appellant contends that Goulet cannot be considered an expert witness because of a lack of computer expertise. ... While frequently considered as an aspect of legal relevance, the exclusion of logically relevant evidence on these grounds is more properly regarded as a general exclusionary rule (see Morris v. ...