Search - considered
Results 1951 - 1960 of 2930 for considered
FCTD
Her Majesty the Queen v. Amway of Canada Limited/Amway Du Canada Limitée and Amway Corporation, [1986] 1 CTC 138
Other passages in his judgment make it clear that he considered forfeiture to be a penalty arising out of the commission of an offence. ... Therefore the exhaustive and considered response which the issue deserves was not available to me. ...
FCTD
Danzas (Canada) Ltée and Danzas S.A. v. Her Majesty the Queen in Right of Canada, [1986] 1 CTC 174
Desforges saw no need to send this notice to customs brokers or forwarding agents and even considered that it might affect the success of his investigation if he did so. ... Considered after the events of April 11, 1980, all these facts may throw a new light on the matter and suggest that it should have been foreseen. ...
FCTD
Société De Gestion Richelieu Inc. v. Her Majesty the Queen, [1986] 1 CTC 342, 86 DTC 6149
Boilard stated in his testimony that in order to determine the increase in value of plaintiff’s land in particular, he considered sales 1, 4 and 7 of his report. ... Gaétan Ménard, plaintiff's second witness testified that to his personal knowledge sales 12 and 14 of the plaintiff’s expert's report cannot be considered as true value of land because he personally saw trucks, over a period of two weeks deliver earth to fill the land which was next to subject land, thus inferring a cheaper price for the land. ...
FCTD
Her Majesty the Queen v. DRS Eugène Lalande and Hubert Watelle, [1983] CTC 311, 83 DTC 5351
Toutefois, comme le faisait remarquer le Juge Pigeon dans l'affaire Freud précitée: It is, of course, obvious that a loan made by a person who is not in the business of lending money is ordinarily to be considered as an investment. It is only under quite exceptional or unusual circumstances that such an operation should be considered as a speculation. ...
FCTD
Winnifred M Hillis and Irvin Hillis, as Administrators of the Estate of William Edward Hillis v. Her Majesty the Queen, [1982] CTC 293, 82 DTC 6249
His argument may be stated briefly as follows: The order having been made it must be assumed that the Court, as required by section 15 of the Dependants’ Relief Act, considered it to be just to allow the application to be made, notwithstanding that the six-month period from the grant of Letters of Administration for doing so had ended some 21 months prior to the application being made. ... In my view the foregoing explanation for the long delay which occurred in this case cannot be considered to be reasonable justification for that delay. ...
FCTD
Morbane Developments LTD v. Minister of National Revenue, [1981] CTC 490, 81 DTC 5362
., in 1977, in Her Majesty The Queen v Cad boro Bay Holdings Ltd, [1977] CTC 186; 77 DTC 5115 laid down as a test that any amount of business activity giving rise to income would necessarily classify the undertaking as an active business and that for a business not to be considered active it had to be in an “absolute state of suspension.” ... The Court of Appeal has ruled that it is up to the trial judge to review all of the facts and to satisfy himself whether there has been sufficient activity for the income to be considered as income derived from an active business. ...
FCTD
Jean-Paul Gagnon v. Her Majesty the Queen, [1980] CTC 324, 80 DTC 6256
The fact that they were subject to some slight variations foreseen by the judgment due to variable tax rates does not in my view prevent them from being considered as predetermined sums of money within the meaning of the Pascoe case. ... The fact that this can take place does not prevent them from being considered as fixed predetermined payments for the taxation years in question during which the payments were made pursuant to the divorce order. ...
FCTD
Olympia Interiors Ltd. v. R., [1997] 2 CTC 70
David, who had walked away from the examination without its being completed, may have considered she was threatened, but there is no evidence before me that there was an intention to create that perception. ... Procedural steps by a party in an action are not, as the claims of Mary David in these applications would appear to assume they are, considered as the personal responsibility of counsel who represents the party in question. ...
FCTD
SMC Pneumatics (Canada) Ltd. v. M.N.R., [1997] 2 CTC 321
It should also be noted that the letter of assignment shall be considered to not be in force after the expiry date of the application, after the cancellation date of the application or after the date the applicant named in the application goes out of business. ... Canada^, [3] the Supreme Court of Canada considered the role of policy guidelines in the context of the Export and Import Permits Act*. [4] Mr. ...
FCTD
Walker v. Canada (Attorney General), 2022 FC 381
The reviewing court must refrain from “reweighing and reassessing the evidence considered by the decision maker”: Vavilov at para 125. [18] A reasonable decision is one that is based on an internally coherent and rational chain of analysis and that is justified in relation to the facts and law that constrain the decision maker. ... In fact, the memorandum only states that the invoice, receipt and tax information is sufficient for proof of threshold income. [30] In Aryan v Canada (Attorney General), 2022 FC 139 (Aryan), Madam Justice Strickland considered a similar benefits compliance decision of the CRA where that applicant also reported self-employment income of at least $5,000 in 2020. ...