Search - considered

Finney refers to three forms of instalment systems showing the manner in which the cash collections are dealt with: " (a) The first collections are considered a return of cost and no profit is taken until the collection exceeds the cost. (b) The first collections are considered profit and the last collections are considered a return of cost. ... At p. 429, as appears from Exhibit 20, he says: "‘When the collection risk is considered to be extreme it is good practice to defer the recognition of profituntil the entire cost has been recovered.’’ ...

These allowances are considered expenses in calculating net income for taxation purposes. ... Esskay Farms Ltd., [1976] C.T.C. 24, 76 D.T.C. 6010 where section 245(2) was considered. ... Carib had, at the time, the right to be considered a separate corporate entity and the right to make a profit. ...

In the Crown’s view, if the derivative is not linked to such a transaction, the profit or loss on the closing out of the derivative is considered either as resulting from speculation or, by default, as being part of the ordinary business of the taxpayer, and is therefore considered to have been received on income account. In the present case, the respondent submits that, as the swaps were not linked to any transaction or debt obligation of the appellant denominated in a foreign currency that it entered into on its own account, the amount received by the appellant when it closed out the swaps is considered to be part of the business of the appellant and therefore a profit from its business that is taxable as income. ... Characterization of the hedging gain [76]         The respondent submitted that in the absence of any linkage to a capital transaction or a debt obligation denominated in a foreign currency that exposed the appellant to foreign currency risk, the foreign exchange gain is considered to be part of business income. ...

From the time it was decided to undertake mining operations in the Thompson Lake area the Appellant considered it to be an essential element in its projections and plans for such operations that there should be a town immediately adjacent to the extracting and processing operations to house the personnel necessary for those operations and provide the supporting urban facilities. ... C.R. 212; [1965] C.T.C. 165, the President considered the meaning of the phases or activities of mining preceding the delivery of ore to the pit head. ... Conceivably the expenditures of the appellant might be considered as being made by the appellant on a number of separate scientific projects which overlap and thereby give the appearance of a continuing expenditure whereas when one of the multitudinous projects is completed that would be an expenditure on that particular project “once and for all”. ...

Justice Major, writing on behalf of the majority of the Justices of the Supreme Court of Canada stated that:   15     Whether a levy is a tax or a fee was considered in Lawson, supra. ... It also seems to me that the Appellant should be considered to have paid the taxes to the U.S. government that were paid in relation to this amount. ... Also, each member's business-income tax and non-business-income tax in respect of a foreign country is considered to include his or her share thereof paid by the partnership ...

Jamieson announced on April 6 th, 2001 to all auditors during a conference call that "the audit was now considered a criminal investigation... ... Jamieson, that "the audit [of the Applicants] was now considered a criminal investigation" and that Mr. ... [61]            As of April 2001, CCRA considered that the 1998, 1999 and 2000 tax returns of the Applicants should be looked at with possible criminal ramifications. ...

The converse is that processing equipment that is part of a distribution system is considered distributing and not processing equipment. ... Although I will address later whether what was going on at Canaport was processing, what matters in determining whether the Jetty is considered part of the Terminal is whether it was necessary and ancillary to the Terminal’s operation. ... The foundation was part of the processing. [88]         Applying these principles to the connection between the Jetty and Terminal, can the Jetty be considered ancillary and necessary, and part of the integral totality of the operation occurring at the Terminal? ...

Section 3 of the pre-1972 Act (the Act being considered in Poynton, supra), provided: 3. ... In Taylor, Thorson, J. set out eight points to be considered in looking at the question. ... In addition there are specific provisions in the Act, which will be considered later, bringing certain things into income for tax purposes. ...

Since unions are the mechanism by which a significant number of public service employees negotiate the terms and conditions of their work, Parliament considered it appropriate that the cost of membership be deducted from employment income. ... Others receiving pay from the public purse, whether employed or appointed under the provisions of the Public Service Act, were equally affected by the 5% reduction in pay but in their battle to restore former levels of salary or to make gains in the future, they were not armed with a constitutional weapon that could be utilized in order to demonstrate that the effect of the unilateral reduction in remuneration called into question their independence from the legislative and executive branch of government because these individuals and their government-employer had never considered they ever possessed any right to be considered in that manner. ... That Court obviously considered that, by using the machinery of a commission, the system of administration of justice could derive benefit from additional insulation- a degree of separation- between the payor-governments and the judges, either as individuals or, collectively, within the context of their organizations or associations. ...

Setchell to have entered into business contracts in order to be considered to be carrying on a business. ... In the latter case, the expense might be considered an income earning expense.   6.       ...   [46]     Some expenses may be considered as dual purpose expenses. ...