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TCC

The Ottawa Hospital Corporation v. The Queen, 2010 TCC 53

The line between those bodies that will be considered Crown agents at common law and those that will not is anything but precise. ... Miller J. considered a situation involving the appointment of a supervisor under the Education Act, R.S.O. 1990, c. ... No. 564, considered the general agency principle that the principal, and not the agent, should bring the action. ...
TCC

Yudelson v. The Queen, 2009 TCC 80

It is considered objectionable to allow the $15,000 DB pension to be commuted to an RRSP that could permit a greater annuity amount to be paid. ... The transfer for the purchase of the annuity cannot therefore be considered an amount received by the Appellant from the RPP. ... At any rate, subparagraph 8503(2)(a)(iii) allows indexation benefits to be considered LRBs in the absence of both periodicity and equality of payments ...
TCC

Société de Transport de Laval v. The Queen, 2008 TCC 14

The Minister determined that amount on the basis of the Appellant's current expenses as detailed in Exhibit I‑6 (which current expenses he considered as established). ... The Minister determined that amount on the basis of the Appellant's current expenses as detailed in Exhibit I‑4 (which current expenses he considered as established). ... The difficulty here lies in the fact that the user might also be considered a "recipient" of the supply of transportation. ...
TCC

Venneri v. The Queen, 2005 TCC 329

However, the Appellant believes that that capital loss should be considered as a business investment loss, since he contends that 2959‑5451 Québec Inc. was a small business corporation ... Accordingly, the loss incurred by the Appellant in respect of his claim on that corporation may not be considered a business investment loss under the definition of paragraph 39(1)(c) of the Act ... First, the $133,000 amount purportedly used to repay in full the mortgage loan on the property at 100 Île de Mai can hardly be considered as having been borrowed for the purpose of earning income from a business or property. ...
TCC

Naghash v. M.N.R., 2005 TCC 694

This document states that PDFs are considered to be employees of Queen’s University unless they receive their funding from an external source. ... Since PDFs are in training, they are considered by the University to be trainees rather than employees ... However, in the course of his research from accessing the website he ought to have been aware that U of A considered Fellows to be in training and – therefore – trainees rather than employees. ...
TCC

27 Cardigan Inc. v. The Queen, 2004 TCC 448

He then went on to examine 43 sales of condominium apartments in the adjacent building that he considered to be comparable. ... The costs are considered reasonable in the subject market area at the effective date of appraisal. ... He based it on two sales of apartment buildings that he considered to be appropriate comparables. ...
TCC

Flash Courier Services Inc. v. M.N.R., docket 1999-2239-EI

Flash considered matters of experience and the type of vehicle to be used in recognition of the high attrition rate within the industry. ... He also considered it a requirement that he attend at the Flash office before 8:00 a.m. in order to complete the deliveries which were due by noon. ... No. 749, the Federal Court of Appeal considered the case of an individual who worked as an inspector of certain toxic substance detectors. ...
TCC

Spire Freezers Ltd. v. The Queen, docket 95-4000-IT-G

Neither BDI nor Peninsula was looking to make money on the Tremont Apartments project since they considered it a cost of developing the condominium project. [8] Mr. ... At one time he considered that it may be necessary to “roll in a nominal asset to achieve this goal”. ... Gouveia stated that “maybe for a fleeting moment” the Canadians considered retaining the condominium development. ...
TCC

Northwood Pulp & Timber Ltd. v. R., [1996] 2 CTC 2123, 96 DTC 1104

She considered whether or not the silviculture costs were a replacement for the stumpage charge. ... He also considered the annual reports of 49 companies and included that information in the study. ... The type of expenses in issue here have never been considered by any other Court. ...
TCC

Emil Misik v. Minister of National Revenue, [1993] 1 CTC 2360, 93 DTC 172

He also adjusted the actual expense figures of the appellants operation in the years in question to what he considered to be the typical industry average at that time. ... He considered the 80 acres to be undeveloped land. On his visit to the farm he noticed approximately 40 head of cattle, 28 cows and 12 calves. ... Further, the interest factor is a significant one that must be considered and it was not considered in this case. ...

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