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TCC (summary)

Vohra v. The King, 2022 TCC 165 (Informal Procedure) -- summary under Support Amount

The King, 2022 TCC 165 (Informal Procedure)-- summary under Support Amount Summary Under Tax Topics- Income Tax Act- Section 56.1- Subsection 56.1(4)- Support Amount support payments could be considered to be made pursuant to terms of a written separation agreement which had expired The taxpayer and his wife separated in 2010 and on March 6, 2011, entered into separation agreement without legal counsel. ...
TCC (summary)

A-Supreme Nursing & Home Care Services Inc. v. The King, 2023 TCC 39 -- summary under Section 6

Furthermore, although such Act “clearly puts the general responsibility of health care services on the operators of care homes” (para. 44), he considered (at para. 46) that: [T]he FCA’s decision [in HSC] should not be read to suggest that having general responsibility over the provision of health care services is a necessary condition to providing an exempt nursing services supply. … Finding otherwise would lead one to conclude that any service provided by a contractor is a supply of personnel rather than the service actually provided for. ...
TCC (summary)

Sussex Group - Allan Sutton Realty Corp. v. The King, 2024 TCC 1 (Informal Procedure) -- summary under Subsection 227(9)

Sutton, considered that all of such deposits to his account were remuneration received by him, and imposed a late source-deductions remittance penalty under s. 227(9) on the appellant regarding its computed under-remittance. ...
TCC (summary)

Mandic Estate v. The King, 2024 TCC 91 -- summary under Subparagraph 171(1)(b)(iii)

Finally, pursuant to subsection 126(4)(e), a case management judge may make any order that is considered just in the circumstances. ...
TCC (summary)

Mandic Estate v. The King, 2024 TCC 91 -- summary under Paragraph 126(4)(b)

Finally, pursuant to subsection 126(4)(e), a case management judge may make any order that is considered just in the circumstances. ...
TCC (summary)

Grenon v. The Queen, 2021 TCC 30, aff'd in part 2025 FCA 129 -- summary under Paragraph 4900(1)(d.2)

Smith J also rejected an alternative argument of the taxpayer that the units qualified under Reg. 4900(1)(d.2), since that provision inter alia also required that there had been a lawful distribution and, as described above, he considered that this required compliance with the OM exemption, since that was what had been relied upon in the reporting of the distribution to the securities’ commissions. ...
TCC (summary)

Uppal v. The King, 2025 TCC 103 (Informal Procedure) -- summary under Paragraph 146.01(2)(d)

CRA considered s. 146.01(2)(d) did not apply on the basis that there were insufficient funds in their RRSPs on December 31, 2021 to fund the withdrawals. ...
TCC (summary)

Caroni v. The King, 2025 TCC 101 -- summary under Onus

Esri J later found that the taxpayer's motion was a non-suit motion, which failed because the Crown had led sufficient evidence to allow the pleaded issues to be at least considered by the trier of fact. ...
TCC (summary)

Richter & Associates Inc v. The Queen, 2005 TCC 92 -- summary under Subsection 141.01(2)

. … However, the portion of the services and properties in question that was acquired for the purpose of prosecuting the claims of the Participating Creditors would be considered to have been acquired in the course of commercial activities. … The allocation by the Estate of the use of its inputs between its taxable supplies and its other activities (exempt supplies) appears to me to be a fair and reasonable one and it complies with subsection 141.01(5).... ...
TCC (summary)

Global Cash Access (Canada) Inc. v. The Queen, 2012 TCC 173, rev'd in part 2013 FCA 269 -- summary under Financial Service

The above supplies (kiosk provision, cashier services and cheque cashing) were "not so interdependent that they should be considered a single supply" (para. 94), and "none of these elements are a minor part of the supply so as to be incidental" for purposes of s. 138 (para. 96). ...

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