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Results 9951 - 9960 of 14736 for considered
TCC
Charron v. MNR, 87 DTC 98, [1987] 1 CTC 2135 (TCC)
That kind of property is considered a movable and does not require the wife's consent. 4.03.1.3 Moreover, according to the respondent, since the term “security" is not defined in the Act, we must look to its ordinary dictionary meaning. ... He concluded therefore that the third requirement of paragraph 20(1)(bb) had also not been satisfied. 4.03.1.6 With respect to the second requirement of paragraph 20(1)(bb), however, counsel for the appellant alleged that the theory that only the ordinary or grammatical meaning may be considered when the word is not defined in the statute in question nowadays admits of exceptions. ...
FCA
Canada v. Merchant Law Group, 2010 FCA 206
. · Liability under Contract/Liability for Payment: Where a person purchases goods on behalf of another person and the other person is liable to pay for whatever it is that the supplier has sold, the person acting on behalf of the purchaser is considered to be an agent of the purchaser. · Ownership of Property: Generally, an agent does not acquire an interest in any property the agent acquires as agent on behalf of the principal. ... ] [23] Other cases have considered the importance of the ability of an agent to affect the legal position of the principal and the assumption of risk by the principal, and reach the same conclusion. ...
EC decision
Meteor Homes Ltd. v. MNR, 61 DTC 1001, [1960] CTC 419 (Ex. Ct.)
Manaster (supra) held that the receipt of the $32,500 by the Manasters was not income to them but a payment of a capital nature and consequently deductible; but the payment in question should be considered in relation to the instant taxpayer only, because cases can arise where payments may be deductible to the payer and not taxable to the payee, but I do not think that this is such a ease. ... Questions of law can only arise when (as was not the case here) some express statutory direction applies and excludes ordinary commercial practice, or where, by reason of its being impracticable to ascertain the facts sufficiently, some presumption has to be invoked to fill the gap,” goes on to say that ‘‘the ordinary commercial practice in arriving at the profits of a fire insurance company was what was being considered in that case’’, and I think the same conditions exist in the present case. ...
FCA
Newfoundland Light & Power Co. Ltd. v. The Queen, 90 DTC 6166, [1990] 1 CTC 229 (FCA)
When asked why he considered the obligation under a credit note as current liability and the obligation under a warranty as contingent, he said:... the credit note, while it is a liability, is also an existing obligation today. ... If the work is not considered satisfactory by the architect, we reserve the right to cancel your contract and have it carried on by another contractor at your expense. ...
TCC
Powrmatic du Canada Ltée, 94 DTC 1206, [1994] 1 CTC 2274 (TCC)
For the purposes of this section, (a) no amount paid or payable for travel on an airplane, train or bus shall be considered to be in respect of food, beverages or entertainment consumed or enjoyed while travelling thereon; and (b) "entertainment" includes amusement and recreation. ... It cannot really and seriously be considered as part of the writing which is provided in paragraph 67.1 (2)(c). ...
FCTD
Ontario Development Corp. v. The Queen, 89 DTC 5134, [1989] 1 CTC 319 (FCTD)
With respect to the first part of the defendant's submission, the relevant provisions dealing with registration, attachment and perfection of a security interest in the Manitoba Personal Property Security Act are almost identical to the provisions of the Ontario Personal Property Security Act and therefore I see no reasons why Muldoon, J’s comments in the Royal Bank case respecting these provisions could not be considered or applied to the case at hand. ... Therefore, as the Bank's perfected interest has been maintained, the plaintiff's interest by assignment is, by virtue of subsection 23(2) considered perfected as of June 7, 1977. ...
TCC
Kaiser v. The Queen, 95 DTC 13, [1994] 2 CTC 2385 (TCC)
In allowing the appeal, the Honourable Judge Rip considered the meaning of superannuation or pension benefit and at pages 2068-69 (D.T.C. 218) of his judgment stated: I must decide if the respondent is correct. ... M.N.R., [1987] 1 C.T.C. 2434, 87 D.T.C. 336 (T.C.C.), the Honourable Judge Brulé, Tax Court of Canada, considered the relevant statutory provision which provided that moving expenses were deductible only to the extent they did not exceed the taxpayer's income for the year from his employment at the new work location. ...
TCC
Ministic Air Ltd. v. The Queen, 2008 TCC 296
The debts must be considered and found to be uncollectible on an individual basis, and the evidence simply did not demonstrate that that had ever been done. ... Even if the note of May 14, 2001 were considered to be sufficient evidence for the write‑off, it could not support this claim for a refund made in the return for an earlier period. ...
FCTD
Friedberg v. The Queen, 89 DTC 5115, [1989] 1 CTC 274 (FCTD)
As the Review Board required estimates of the fair market value, it must be considered whether the appraisals submitted for the collections are a reflection of the above definition. ... In addition to the traditional buy and sell of commodities futures carried on by many businessmen attempting to ensure either the future delivery of a commodity at a fixed price or a future sale of a commodity at a fixed price, a futures contract is considered to have inherent value and the buying and selling of commodities futures contracts has developed as a method of speculative trading. ...
TCC
Thibeault v. The Queen, 2015 TCC 271
The subsection is worded as follows: (17.2) [Presumed rental]-- For the purposes of subsections (1.11) and (17), gross revenue derived in a taxation year from (a) the right of a person or partnership, other than the owner of a property, to use or occupy the property or a part thereof, and (b) services offered to a person or partnership that are ancillary to the use or occupation by the person or partnership of the property or the part thereof shall be considered to be rent derived in the year from the property. ... [TRANSLATION] 15(r) the Minister considered that the appellant was carrying on a business during the fiscal year ending on October 31, 1995, since, in addition to renting the ship, it provided Navimex with a cruise marketing service by means of its only employee, Guy Gagnon; [58] The Appellant submits that, just as for Mr. ...