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Results 1641 - 1650 of 2927 for considered
FCTD
Canada Permanent Mortgage Corp. v. MNR, 71 DTC 5409, [1971] CTC 694 (FCTD)
This is an old established Toronto company, has been in business for about 125 years, has gas franchises in various areas of Ontario and is considered a high-grade conservative stock. ... This is a well-established Canadian company and is considered to be a very conservative investment. ... What is the line which separates the two classes of cases may be difficult to define, and each case must be considered according to its facts; the question to be determined being—Is the sum of gain that has been made a mere enhancement of value by realizing a security, or is it a gain made in an operation of business in carrying out a scheme for profit-making? ...
FCTD
Mobil Oil Canada Ltd. v. Canada, docket T-1260-90
" any amount (other than a prescribed amount) paid or that became payable payable in the year by virtue of an obligation imposed by statute or a contractual obligation substituted for an obligation imposed by statute to (i) Her Majesty in right of Canada or a province, (ii) an agent of Her Majesty in right of Canada or a province, or (iii) a corporation, commission or association that is controlled, directly or indirectly in any manner whatever, by Her Majesty in right of Canada or a province or by an agent of Her Majesty in right of Canada or a province as a royalty, tax (other than a tax or portion thereof that may reasonably be considered to be a municipal or school tax), lease rental or bonus or as an amount, however described, that may reasonably be regarded as being in lieu of any such amount, and that may reasonably be regarded as being in lieu of any such amount, and that may reasonably be regarded as being in relation to (iv) the acquisition, development or ownership of a Canadian resource property, or a property that would have been a Canadian resource property if it had been acquired after 1971, or (v) the production in Canada of (A) petroleum, natural gas or related hydrocarbons, or (B) metal or industrial minerals to any stage that is not beyond the prime metal stage or its equivalent from an oil or gas well or mineral resource situated on property in Canada from which the taxpayer had, at the time of such production, a right to take or remove petroleum, natural gas or related hydrocarbons or a right to take or remove metal or minerals. 18(1)(m) Redevances, etc. ... I have considered carefully permitting deductibility of royalties and I have concluded that this approach does not offer a practical solution. ... The expression "royalty", as it was considered by the Supreme Court in Imperial Oil, was only considered in the context of the contractual relationships between the parties which arose by reason of a lease and a farm-out agreement. [9] After careful consideration of the authorities to which both sides referred me, I am of the view that the position taken by the Defendant is correct. ...
FCTD
Lalonde v. Canada Revenue Agency, 2010 FC 531
[40] All things considered, the delegate’s reasoning is very simple. ... [43] The other factor that the delegate considered is in subparagraph 10(b): (b) whether or not the taxpayer has knowingly allowed a balance to exist on which arrears interest has accrued; … [Emphasis added.] ... The relevant, but not exhaustive, factors to be considered in deciding the first question are set out in paragraph 6, notably subparagraph 6(b), which the delegate determined to be inapplicable as an example of an action of the Agency, because Mr. ...
FCTD
Lavigne v. Canada (Justice), 2009 FC 684
Lavigne’s complaint was considered under paragraph 77(1)(a) of the PSEA: 77 ... [68] To avoid the appearance of unfairness, definitions must be established before the review of the job applications of the persons being considered for appointment. ... While we may agree that the word “approximately” lacks a certain precision and may be considered to be vague, this flexibility may well serve the needs of the appointment process ...
FCTD
Canada v. Malachowski, 2011 FC 413
Mosley granted the interim charging order on Nun’s Point and ordered the matter to be further considered by the Court on April 15, 2010. ... [6] Justice Mosley’s Order provided: IT IS ORDERED that unless sufficient reasons to the contrary are show on April 15, 2010 at 9:30, when this matter will be further considered by the Court at Ottawa, Mr. ... Rule 458 and Equitable Interests in Land [63] In Re Laquerre, 2008 FC 460 (Laquerre), Justice Martineau considered a challenge to having an interim charging order made absolute. ...
FCTD
Connolly v. Canada (National Revenue), 2017 FC 1006
He discussed other case law, including Dimovski v Her Majesty the Queen, 2011 FC 721 [Dimovski], which he considered relevant to a request for relief. ... Respondent’s Submissions [38] The Minister’s counsel submitted that “reasonable error” could not be based upon ignorance of the law or reliance upon third party conduct, citing case law that is considered below. ... As a result, the Court considered means to assist the Applicant out of his predicament. ...
FCTD
Morris v. Canada (Attorney General), 2019 FC 1374
[22] As stated by the Federal Court of Appeal in Wannamaker: [5] Section 39 ensures that the evidence in support of a pension application is considered in the best light possible. ... Further, the Appeal Panel considered the medical evidence and used a clear and explicit framework to assess the credibility of the letters from Dr. ... Further, s 39(b) of the VRAB Act required the Appeal Panel to accept any uncontradicted evidence presented by the Applicant that it considered to be credible. ...
FCTD
Agt Limited v. Attorney General of Canada, [1996] 3 CTC 143
Having considered Richardson and McKinlay, I conclude: 1. The expectation of privacy in relation to business records is relatively low. 2. ... In applying these principles, the Commission has considered a number of factors. The Commission goes on to give examples of the matters it considered. ...
FCTD
Michaels of Canada, ULC v. Canada (Attorney General), 2022 FC 1498
MoC asserts in its NOA that the ruling officer considered all payments under the 2003 licence agreement to be non-dutiable. ... Issues [33] Having considered the parties’ written material and their oral submissions, I find that the issues for the Court to determine on this motion are two-fold: A. ... In particular, MoC submits that the issues it raises with the judicial review application otherwise will not be considered because the CITT has found that “reason to believe” is not relevant to the issue of whether “value for duty” was correctly determined. ...
FCTD
Lawrence H Mandel/ v. Her Majesty the Queen, [1976] CTC 545, 76 DTC 6316
The fact that it invested £70,000 sterling in 1964 in the film indicates to him that they must have considered it had great potential. ... He referred also to Kohler’s Dictionary for Accountants which defines contingent liability as one “due only on failure to perform a future act” stating that he did not consider that this is such a case, and pointed out that the bank and Niagara Television Limited evidently considered the advances to be an appropriate commercial loan, and that at the time the Canadian Film Development Corporation evidently considered their advances as an investment even though somewhat risky. ... He also referred to what the witnesses admit to be the leading textbook in Canada, Skinner’s Accounting Principles at page 412 in which the author states: To the extent that liability under the contingent payment clause was considered likely provision for it should be made by the purchaser. ...