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Results 2941 - 2949 of 2949 for considered
FCTD
Blue Bridge Trust Company Inc. v. Canada (National Revenue), 2020 FC 893
., 2019 SCC 4, [Metro Vancouver] at para 4. [57] Blue Bridge also suggests that the CRA has admitted that in the case of a discretionary trust, a person is considered a beneficiary only when he or she directly or indirectly receives a discretionary distribution from the trust. [58] A decision from the Administrative Court of Appeal of Paris has allegedly also recognized that the assets of an Anglo-Saxon trust are separate from the asset base of the beneficiary, in addition to confirming that the trustee is the one who has ownership of the trust’s assets: Administrative Court of Appeal, No. 16PA01660, Paris, October 12, 2017. ...
FCTD
Special Risk Holdings Inc. v. Her Majesty the Queen and Minister of National Revenue, [1994] 1 CTC 274, 94 DTC 6151
I think it’s quite clear and if this is not a sufficient admission for my friend, we can talk about it some more, but up to and including the careful review of this proposal by Verchere, when he suggested a two-step approach to the 51/49, nobody considered anything other than 51/49, neither Mr. ...
FCTD
Maurice Moloney, Raymond L. Young, Gary A. Russell and Steven S. Fullard v. The Queen, [1989] 1 CTC 213, 89 DTC 5099
It might perhaps be said that it met the "busi ness" test and the "reasonable expectation of profit” test if only Canadian operations are considered. ...
FCTD
Canada (National Revenue) v. Miller, 2021 FC 851
I have considered the Minister’s request and the factors set out in Rule 400(3) in light of the mixed result in this application and will award costs to the Minister in the amount of $1,250.00. ...
FCTD
Nathaniel C Brewster v. Her Majesty the Queen, [1976] CTC 107, 76 DTC 6046
Mr Ward: Are there any that were considered relevant to the Minister in making assessments? ...
FCTD
Adelberg v. Canada, 2023 FC 252
I find that this NOCC is analogous to the Statement of Claim considered by Justice K. ...
FCTD
Thomson v. Canada, 2003 FCT 83
Cormack enclosed what he considered the accounting he had agreed to. That was a statement of account. ...
FCTD
CC Havanos Corp. Ltd. (Re), 2002 FCT 941
This is the kind of deference the Court owes to Parliament, which down through the years has considered the forfeiture of such property, draconian as it may appear to be from time to time, to be a measure that it is right and necessary to retain ...
FCTD
James Peter Lovell v. Her Majesty the Queen and Angelo Turchetta (Intervenor), [1990] 1 CTC 443, 90 DTC 6116
D'Henricourt, Vente des immeubles par décret, says that he, knowing that his property has been seized on a third person and being informed of this in a manner the law prescribes, takes no step to oppose the sale, is considered to have consented to the sale. ...