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Results 191 - 200 of 269 for considered
TCC (summary)
Mullings v. The Queen, 2017 TCC 133 (Informal Procedure) -- summary under Paragraph 118.3(1.1)(d)
. … [M]easuring and controlling Phe intake is properly characterized as administration of the therapy and not as control of X’s diet with the consequence that the correct way to apply these rules [in subsection 118.3(1.1)] is to consider that the time spent determining the amount of Phe to be consumed and actually consumed, including the time spent logging Phe intake, should be considered as part of the 14‑hour a week average. ...
TCC (summary)
Nelson v. The Queen, 2017 TCC 178 (Informal Procedure) -- summary under Subsection 325(1)
The taxpayer considered half of the funds so transferred as hers and as a loan, and the taxpayer and her husband had an oral agreement respecting monthly repayments that would be made upon the Company becoming profitable. ...
TCC (summary)
Lavrinenko v. The Queen, 2017 TCC 230 (Informal Procedure), aff'd 2019 FCA 51 -- summary under Shared-Custody Parent
The Queen, 2012 TCC 240, Campbell J. considered that Parliament intended that the words “near equal basis” in the definition of “shared-custody parent” to mean “only a small difference between the amounts of time spent with each parent”. ...
TCC (summary)
Markou v. The Queen, 2018 TCC 66, aff'd on selected grounds 2019 FCA 299 -- summary under Subsection 248(30)
In the Markou case, Paris J found (at para. 108) that “ donative intent in civil law, as in common law, is always an essential element of a gift, even a partial gift,” whereas here “there was just one interconnected transaction and no part of it can be considered a gift that was given in expectation of no return” (para. 109). ...
TCC (summary)
Poirier v. The Queen, 2019 TCC 8 -- summary under Subsection 262(1)
The wording is quite technical and must be considered “mandatory as opposed to directory:” Chandra v R, 2009 TCC 230, para. 4. ...
TCC (summary)
Zdzieblowska v. The Queen, 2019 TCC 40 (Informal Procedure) -- summary under Subsection 296(2.1)
. … Since the Appellant was assessed, pursuant to subsection 297(2.1), an amount payable of $24,000 under section 264, the Minister should have considered subsection 296(2.1) when issuing the assessment in respect of the New Housing Rebate. ...
TCC (summary)
Villa Ste-Rose Inc. v. The Queen, 2019 TCC 60, aff'd 2021 FCA 35 -- summary under Subsection 296(2.1)
D’Auray J considered this approach to be unfair and anomalous, given that if the company had not claimed the rebate amounts, on assessing, CRA would have been required under s. 296(2.1) to allow the (more than) offsetting unclaimed rebate amounts, so that no interest or penalties could have been assessed by it. ...
TCC (summary)
Lounsbury v. The Queen, 2019 TCC 109 (Informal Procedure) -- summary under Subparagraph 256(3)(a)(iii)
Respecting the first ground, he stated (at paras. 23, 29-30): While the first occupancy certificate is not in itself determinative, the fact that it permits residential occupancy combined with the relatively minor list of items that are required to be done before issuance of a final certificate are significant factors to be considered. ...
TCC (summary)
Lilyfield Development Inc. v. The Queen, 2020 TCC 16 -- summary under Subsection 169(1)
Similarly to the corresponding provision of the Ontario Business Corporations Act considered in 1455257 Ontario, s. 219(2)(a) of the Corporations Act of Manitoba provided that a proceeding commenced by a corporation before its dissolution could be continued as if it had not been dissolved. ...
TCC (summary)
DiCaita v. The Queen, 2021 TCC 5 (Informal Procedure) -- summary under Income-Producing Purpose
In rejecting the Crown’s submission that the repair expenditures were not deductible because the unit was not rented out during that year, Masse DJ noted (at para. 23) that “a property does not need to be generating income at every stage of operation in order to be considered a source of income.” ...