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Results 1631 - 1640 of 2927 for considered
FCTD
Zone3-XXXVI Inc. v. Canada (Attorney General), 2016 FC 75, rev'd 2016 FCA 242
It must be assumed that the Minister considered all the evidence on file and the applicant’s arguments that the Production is similar to previous productions featuring “games of skill and chance, as well as quizzes” that CAVCO considered to be eligible in the past. ... Empty or boilerplate phrases such as “the evidence, precedents or relevant factors were considered by the decision-maker” are not sufficient to allow the reviewing court to determine whether the outcome is an acceptable one. ... Prolonged set-up to a challenge should still be considered part of the challenge. • If the winner of each episode of a series returns in the next episode until they are beaten by a new challenger, it is still considered to have new contestants in every episode. ...
FCTD
Zale Canada Diamond Sourcing Inc. v. Canada, 2010 FC 202
[2] This appeal, pursuant to section 81.2 of the ETA, is to be considered de novo and under the Federal Courts Rules, proceeds by way of an action and is not a judicial review of the Minister’s decision not to accede to the refund request. Consequently, there is no standard of review to be considered and applied. ... As stated in Reference re Firearms Act, "it is now well accepted that the legislative history, Parliamentary debates, and similar material may be quite properly considered as long as it is relevant and reliable and is not assigned undue weight [emphasis added]" (at paragraph 17) ...
FCTD
Rémillard v. Canada (National Revenue), 2020 FC 1061, aff'd 2022 CAF 63
Rémillard submits that his tax information must be protected because a large part of it reveals, even indirectly, his identity and therefore is considered private information. ... As Hunter teaches, for a seizure to be considered reasonable, an individual’s reasonable expectation of privacy must be balanced against the competing law enforcement interest of the state (the government). ... As Justice Stratas observed in Lukács, section 318 of the FCR should not be considered in isolation. ...
FCTD
Norman A. Mintzer v. Her Majesty the Queen, [1995] 1 CTC 220, 95 DTC 5131
Two points must be considered in order to answer these questions. First, the direct action in nullity brought pursuant to article 33 of the Code of Civil Procedure, R.S.Q., c. ... To decide whether the La Champenoise facilities were used as a reception centre strictly speaking, Bisson C.J.Q. considered in particular the criteria for admission to the establishment. ... It is implicit from his reasons that 1964 is the year to be considered in fixing a starting-point for the activities of La Champenoise as a reception centre. ...
FCTD
Rémillard v. Canada (National Revenue), 2022 FC 338
The BRA is asked whether the applicant is known to it, whether the applicant is considered to be a tax resident of Barbados, whether he reported his income during the audit period and whether he has been the subject of a tax audit. ... Three requests for information regarding transactions indirectly related to the applicant were sent to a Barbadian company that was considered a Canadian resident for tax purposes; c. ... Robichaud did not press the matter further if he considered the requested information to be relevant to the current audit. ...
FCTD
Iggillis Holdings Inc. v. Canada (National Revenue), 2016 FC 1352, rev'd 2018 FCA 51
The joint client relationship has always been considered to comply with SCP doctrine, as shall be discussed below. ... This serves as a ground to reject the theory that CIP can be considered to be a defence to the waiver of SCP. ... Reference has already been made to the Ambac decision where CIP was considered an “exception” to waiver. ...
FCTD
MNR v. Enjay Chemical Co. Ltd., 71 DTC 5293, [1971] CTC 535 (FCTD)
The question was again considered by Dumoulin, J. in the case of Galipeau v. ... In considering whether the results of any transaction can be considered in computing the profit of a business for a particular year, the first question is whether it was entered into for the purpose of gaining or producing income from the business (compare Section 12(1) (a)). ... Dunlop testified that no change could be made since this was not considered as a reduction in price. ...
FCTD
Kit-Win Holdings (1973) Ltd. v. The Queen, 81 DTC 5030, [1981] CTC 43 (FCTD)
As the Lord Justice Clerk pointed out each transaction must be considered according to its particular facts. The transaction which gave rise to the disputed assessment herein was participation by the plaintiff in the syndicate (which is identified as the Trafalgar syndicate) which realized a gain on the sale of real estate purchased by it and it is the facts of this transaction upon which the taxability of the gain realized must be considered and determined. ... As previously recited Mr Campbell considered this to be a most desirable property because of its location, zoning and above all because it was inexpensive. ...
FCTD
AEL Microtel Ltd. v. The Queen, 84 DTC 6374, [1984] CTC 387 (FCTD), rev'd 86 DTC 6348, [1986] 2CTC 108 (FCA)
The same issue was considered by the Appeal Division in The Queen v Canadian Pacific Limited, ([1977] CTC 606; 77 DTC 5383). ... It is clear that the Chief Justice considered it inappropriate to extend the meaning of the word “received” to include the advantage provided in the provincial legislation. ... It is a rule of construction that, where in the same Act, and in relation to the same subject matter, different words are used such choice of different words must be considered intentional and indicative of a change in meaning or a different meaning. ...
FCTD
Bowater Power Co. Ltd. v. MNR, 71 DTC 5469, [1971] CTC 818 (FCTD)
There there- fore appears to be very little to distinguish a lease from a licence if the criterion of exclusive possession is considered. ... In the case of a business transaction like this, I think that the question whether a man ought to be considered as a licensee or a tenant depends principally, if not entirely, on whether he has exclusive possession of the property in question. ... I do not indeed feel that merely because the expenditure was made for the purpose of determining whether to bring into existence a capital asset, it should always be considered as a capital expenditure and, therefore, not deductible. ...