Search - considered

Any customer warranty was provided by the manufacturer of the cell phone but Balanko stated he considered customers who dealt with him to be his own clients. ... Peters stated she considered her services had to be provided personally and, when working with Quaife, one of them always ensured the store was staffed. ... No. 239, I considered the matter of a worker who was engaged in selling pay phone installations to businesses. ...

Given the problems it was facing, the Appellant considered it unlikely that it would be able to use the Tax Attributes at any future point. ... The Appellant said that the income earning activities could not be considered as part of the series of transactions, and that, while the Tax Attributes were preserved by the series of transactions, their preservation does not constitute a reduction, deferral or avoidance of tax. ... These circumstances: reflect the intention that a dilution of control, or a loss of control by a person or group of persons to an undefined group, will not be considered offensive except in certain contexts, such as an amalgamation or a reverse takeover. ...

In that case, the Master of the Rolls considered these two classes of payments made by the English company to the French company, in the light of the House of Lords decision in Constantinesco v. ... It is only under exceptional circumstances that it must be considered income, especially after the above considerations. ... We find it difficult to extract any clear principle from the decided cases, except that all relevant circumstances must be considered, which is not particularly helpful. ...

Brossard testified that CAE did not include in its income the amounts received as contributions under the SADI Agreement, because CAE considered them amounts received from a loan and not received as "government assistance" [61]. ... (a) Average duration to expiry date (59) Mr. de Gray considered the SADI Agreement had a 20-year term, i.e. a five-year contribution period followed by the 15-year reimbursement period. ... Finally, he examined the manner in which CAE treated the SADI Agreement in its financial reports. (133) The interest rate for a financial instrument considered to be risk-free is useful for the analysis to be performed by the Court. ...

The search was part of an investigation into what Revenue Canada considered a tax scheme. ... She considered the appearance and weight of the box, which was made of solid silver. ... The concept of fair market value has been considered by the courts, inter alia in Henderson v. ...

In the first stage of the 2018 section 58 reference, the Court allowed the Follow-Up Question to proceed to be considered and answered. ... In paragraph 14, the Court wrote: A sum is considered certain when it can be made certain. ... In several provisions a “note” is expressly considered indebtedness or a debt obligation. ...

Prior to 1994, he rode the bus to work and considered he may have done so in later years if he had not been provided with the parking pass ... Barnes considered it was more convenient to use his own vehicle to travel to and from work. ... Amelio lived within 2 blocks of a bus stop but had not considered public transit as a viable alternative. ...

Amounts spent for nutritional items, vitamins and supplements are not considered eligible medical expenses nor are repairs to a wheelchair. ... Both the purpose and the effect of the legislation must be considered in determining the appropriate comparison group or groups. ... The Court considered whether that distinction constituted a violation of s. 15(1) of the Charter. ...

Therefore the object of the new legislation was to ensure that the business of a corporation that invested in rental properties would not be considered “active” unless there was sufficient activity in the corporation’s business to justify the employment of over five full- time employees. ...

  [3]    A taxpayer may be considered to have served notice of objection as required by section 169 only if he has served the notice within the time period set out in subsection 165(1) of the Act, that is to say on or before the later of   (i)  the day that is one year after the taxpayer’s filing-due date for the year, and (ii) the day that is 90 days after the day of mailing of the notice of assessment; and …   [4]    The affidavit of Cheryl Ritchie establishes that the assessment from which the Appellant appeals was mailed on December 8, 2003 to his last known address as indicated in his return of income for the 2000 taxation year ...