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FCTD

Khosroabadi v. Canada (Attorney General), 2025 FC 1106

This document was before the decision-maker and is therefore admissible to be considered. [21] Two of the documents are eligibility criteria from the CRA’s website that counsel for the Respondent agrees were operative at the relevant times. ... Khosroabadi also argued that her evidence was not considered and this made the decision unfair. ... Khosroabadi has not pointed to anything specific that was not considered by the Second Reviewer. [33] My role on judicial review is limited. ...
FCTD

Coley v. Canada (National Revenue), 2017 FC 210

The affidavit of the TRO describes the information she considered and the assessment she conducted. ... The Applicant does not point to any errors in the documents on the record considered by Ms. ... Factors to be considered when waiving or cancelling penalties and/or interest Facteurs à considérer au moment d’annuler les pénalités et/ou les intérêts, ou d’y renoncer 15. ...
FCTD

Echo Bay Mines Ltd. v. The Queen, 92 DTC 6437, [1992] 2 CTC 182 (FCTD)

It was considered then that prices prevailing in 1980 were favourable, and that risk of their decline in future should be avoided. ... Yet, even if the forward sales contracts were considered hedging the transactions were not sufficiently integrated with production and delivery of the silver product that they could be considered to constitute a single business activity. ... Parsons that for accounting purposes the gain or loss from hedging transactions to the extent of actual production could be considered production revenue, while any excess gain related to estimated production that did not in fact occur must be considered investment income. ...
FCTD

Easton v. The Queen, 92 DTC 6218, [1992] 1 CTC 334 (FCTD), aff'd 97 DTC 5464 (FCA)

Generally, a loan made by a person who is not in the business of lending money is to be considered as an investment. ... The guarantees are to be considered as deferred loans by the plaintiffs to the two companies. When they were called upon to repay, their loss must be considered a capital loss. ...
FCTD

D'Urzo v. Canada Revenue Agency, 2011 FC 951

  [12]            She then summarized what she considered to be the issue and the evidence she considered in coming to her conclusion.  ... Was the Decision Reasonable (Were all Allegations Considered)?   [41]            For the most part, a consideration of whether all of the Applicants’ allegations were considered is subsumed in the adequacy of reasons analysis.  ... The Applicants also argued that the Decision Reviewer should have considered that Ms.  ...
FCTD

Bonnybrook Park Industrial Development Co Ltd v. Canada (National Revenue), 2022 FC 103

The Minister’s Delegate also considered any limitations on the relief they could consider. ... Bonnybrook did not contest this interpretation. [32] The Minister’s Delegate considered whether the health conditions of Ms. ... Bonnybrook argued that its references to these challenges should have been considered by the Minister’s Delegate. ...
FCTD

Gulf Canada Resources Ltd. v. The Queen, 93 DTC 5345, [1993] 2 CTC 198 (FCTD)

Three cases were referred to by counsel in which subsection 1100(14) has been considered. ... M.N.R., [1985] 1 C.T.C. 2367, 85 D.T.C. 322 (T.C.C.), the same issue was considered involving the same building for a subsequent taxation year. ... (an) important factor to be considered is the proportion of the amount of space rented in relation to the total area of the building. ...
FCTD

Brant v. Canada, docket T-528-98

This connecting factor weighs against the refunds being considered as situated on the reserve. 2. ... This would tend to weigh against the rebates being considered as situated on the reserve.      ... All other factors are neutral or weigh in favour of the rebates being considered situated off the reserve. ...
FCTD

Saber & Sone Group v. Canada (National Revenue), 2014 FC 1119

The affidavit explains Ms Taylor’s role as an Appeals Officer and the information she considered in reaching her decision. ... While the latter issue is one of procedural fairness, both issues have been considered together. ... That Memo cryptically sets out the information Ms Taylor considered, but does not suggest that she was advised by the Helpdesk to revoke the applicants’ privileges. ...
FCTD

Lydford v. Canada (Canada Revenue Agency), 2025 FC 627

We have completed our review and have carefully considered all the information available. ... There is no evidence adduced in this proceeding that permits the Court to determine whether the decision-maker considered the Applicant’s arguments, which facts were considered, or how the decision-maker justifies its decision in light of the facts and the applicable law. ... Its outcome cannot be considered reasonable in light of its serious shortcomings and failure to grapple with the key issue argued by the Applicant. ...

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