Search - considered

Filter by Type:

Results 8371 - 8380 of 14787 for considered
T Rev B decision

Metropolitan Properties Limited v. Minister of National Revenue, [1974] CTC 2127

The roads were in an unfinished condition, there were many mud streets in Transcona itself, as well as many buildings without indoor plumbing facilities, and it was not considered one of the prime residential areas of what is now the metropolitan area of the City of Winnipeg. ...
T Rev B decision

Robin E Anderson, Patrick M Reynolds, Herman Hagerman Huestis and Keith E Steeves v. Minister of National Revenue, [1974] CTC 2135, 74 DTC 1103

The consideration received should be considered as a settlement of the damage claim which (the appellants) would otherwise have been able to present for the wrongful cancellation of (their) option(s) which would otherwise have occurred from the implementation of the shareholders’ resolution of Bethex passed January 23, 1969, providing for the liquidation of Bethex. ...
T Rev B decision

Estate of Donald Murdoch Clouston v. Minister of National Revenue, [1974] CTC 2163, 74 DTC 1176

Clause 4 of the will reads in part as follows: All the rest and residue of my estate of whatsoever nature and kind and wheresoever situate, of which I may die possessed, including the balance of my life insurances as in paragraph 3(d) provided, is to be invested as hereinafter directed, and from the net annual income derived therefrom the sum of Nine Thousand Six Hundred Dollars ($9,600) per year, payable In monthly instalments, shall be paid tax free to my said beloved wife for and during the remainder of her life, together with any other amount as may in the discretion of my executors and trustees be required to maintain my beloved wife in the station in life to which she is accustomed, including provision for such occasional trips as may not be considered unreasonable by my executors and trustees having regard to the Income of the estate at the time and depletion of the estate If any, PROVIDED HOWEVER, that in the event of my beloved wife remarrying then the benefits provided under this clause in no circumstances in any one year exceed in total the sum of Twelve Thousand Dollars ($12,000) including provision for occasional trips. ...
T Rev B decision

Russell Zarbatany v. Minister of National Revenue, [1974] CTC 2195, [1974] DTC 1134

At the hearing, the appellant stated that before the separation he had paid in property costs, mortgages, principal and interest the sum of $123 a month on property belonging exclusively to his wife, and that the postdated cheques for this amount should therefore be considered alimony payments. ...
T Rev B decision

Seto Holdings LTD v. Minister of National Revenue, [1974] CTC 2347, 75 DTC 1

I cite as a couple of examples the fact that he considered general averages, as produced in a pamphlet by Dun & Bradstreet as to percentage of return of earnings on the net tangible assets of a company in the restaurant business. ...
BCCA decision

Minister of Finance v. First National Bank of Nevada (Representative of the Late Hugh Herbert Wolfenden), [1973] CTC 187

It follows, he argues, that if in 1921 the Legislature had enacted a provision excepting shares of deceased members from those transferable on a branch register, the provision would merely have had the effect of preserving for the province a right of taxation which it already possessed and could not therefore be considered properly as colourable legislation. ...
FCTD

Estate of Paul Dontigny v. Her Majesty the Queen, [1973] CTC 529, 73 DTC 5398

In any case, at the death of Mr Dontigny his immovables became “vested indefeasibly in his spouse”, and consequently paragraph 7(1)(a) authorizes the deduction claimed even if the will creates a substitution: (a) Subsection 7(2) stipulates that a superannuation benefit payable to the spouse of a deceased, in respect of the death of the deceased, “subject to a provision that such benefit ceases to be payable to such spouse if he remarries, shall not, by reason only of such provision, be considered not to be vested indefeasibly in him”. ...
FCTD

Le Soleil Limitee v. Minister of National Revenue, [1972] CTC 244

Payment for space reserved in a newspaper by an advertiser is, in respondent’s submission, payment for services rendered, and a printer’s income from this source cannot be considered as income from the sale of manufactured and processed goods within the meaning of section 40A of the Act. ...
FCA

Minister of National Revenue v. Roland O Bartlett, [1972] CTC 333, 72 DTC 6293

This would seem to be a more reasonable interpretation of Section 83(2) than it would be to conclude that because the amounts of the annual payments were based on production from the property they must be considered as a “royalty or similar payment” even though the taxpayer had divested himself of all proprietary interests in the property. ...
SCC

Minister of National Revenue v. James a Cameron, [1972] CTC 380, 72 DTC 6325

He further emphasized that the title which was so conferred upon the respondent (which was the same as he had held as an employee of Campbell Limited) was deliberately bestowed in order that customers of Campbell Limited would be unaware of any change in the conduct of the business of Campbell Limited which he considered would be detrimental to the conduct of that business. ...

Pages