Search - considered

Results 331 - 340 of 7924 for considered
TCC

Industries S.L.M. Inc. v. Minister of National Revenue, [1996] 2 CTC 2572, 96 DTC 3215

Determinate and limited succession of like things forming a whole, or considered as such.... ... A number of authors have considered the meaning of the expression “series of transactions” [12] in the context of the new section 245. ... In other words, the point to be determined is whether, under the circumstances, S.L.M. can reasonably be considered to have artificially or unduly created a loss? ...
TCC

Sears v. The Queen, 2009 DTC 1370, 2009 TCC 344 (Informal Procedure)

The fact remains, though, that each case must be considered on its own facts, by weighing and balancing all of the relevant factors. ... Minister of National Revenue, [1964] S.C.R. 209, [1946] C.T.C. 51, 2 DTC 812 (S.C.C.), the meaning of the words "ordinarily resident" in paragraph 9(a) of the Income War Tax Act was considered. ... No. 158 (QL), Justice Campbell considered the appeal of a pipe welder who kept a home in Nova Scotia but travelled on four different occasions during the year at issue in order to obtain work. ...
TCC

Dibro Investments Ltd. v. MNR, 87 DTC 210, [1987] 1 CTC 2281 (TCC)

The present case is, in my opinion, analogous to that considered by the Supreme Court of Canada in Time Motors Limited v. ... The credit note should not be considered apart from the transaction out of which it arises. ... That obligation must be considered as subsisting until satisfied or expired. ...
TCC

Poulin v. M.R.N., 2012 TCC 415

Therefore, she could not be considered part of a group of dancers with mediocre pay ... She admits that becoming an employee was advantageous for her, but she claims that she had always considered herself an employee, even when she was paid by fees. ... The dance world must be considered in a special context. Employees know they must work a lot to have some recognition and that remuneration is not always adjusted for the hours worked ...
TCC

Al-Mosawer v. M.N.R., docket 96-2207-UI

Houle concluded that the appellant’s employment was not insurable mainly because he considered that her salary was too high for 1991. ... Kazzaz’ brother-in-law (having married his sister) would then be considered connected to him by blood relationship (as a brother would be) according to paragraph 251(6)(a). ... Waly would be considered connected by marriage because she was married to a person (Mr. ...
TCC

Beaudry v. The Queen, docket 96-2222-IT-G

One of the reasons the Minister considered the debt not to be bad in 1982 was that in calendar year 1983 Mirage paid dividends of $149,486. In assessing the appellant for 1983, however, the Minister considered the debt to have become bad in 1983 but was a capital loss. ... An advance or outlay made by a shareholder to or on behalf of the corporation is also generally considered to be on capital account. [7] The same considerations, wrote Robertson, J.A. in Easton et al. v. ...
TCC

Dickie v. The Queen, 2012 TCC 327

Canada, 2011 SCC 39, [2011] 2 S.C.R. 764, which effectively changed the weight and importance of one of the traditionally considered factors to be considered in the “connecting factors” test; namely, the commerciality of the business thus creating a new dynamic in the application of the connecting factors test. ... The nature of the Appellant’s business in this case involved a larger business that clearly competed with non-aboriginal businesses in what has been traditionally considered in the commercial mainstream; a case of head to head competition between an aboriginal business and non–aboriginal competitors. ... It is in the nature of the test that all evidence must be considered with a view to determining whether income was situated on the Reserve or not, including with respect to the several other factors constituting the connecting factors test. ...
TCC

Sirois v. The Queen, docket 98-1988-IT-G

As a result, we object that these amounts be considered as appropriation of funds.... ... We consider that this amount is included in Régis Sirois' 1993 income totalling $43,126, and that it cannot in any way be considered income earned by the outfitting business Le Chasseur Inc.... ... We also object that the expenses incurred by the outfitting business Le Chasseur Inc. for the rental of the Ford 4 x 4 be considered appropriation of funds since that vehicle was needed for the company's business operations. ...
TCC

Devries v. M.N.R., docket 2001-3051-EI

I say yet again because since its passage in 1990, several decisions of the Tax Court of Canada and several judgments of this Court have already considered what workable meaning could be given to subparagraph 3(2)(c)(ii). ... No. 30, I considered the case of three brothers, each of whom owned 16% of the voting shares in the payor. ... Those factors- while relevant- do not detract from the overall analysis of various indicia of employment considered by the Minister in the course of discharging the duty required by paragraph 5(3)(b) of the Act. ...
TCC

Houda International Inc v. The Queen, 2010 TCC 622, [2011] GSTC 8

., [1978] 2 S.C.R. 516, Pratte J. considered the concept of impossibility in fact and wrote, at pages 526 and 527:  . . .  ... Issue Estoppel and Abuse of Process   [17]          Issue estoppel and abuse of process were considered at length in Golden et al. v. ... (as he then was) considered whether he was bound, by reasons of judicial comity, to apply a decision of Noël J. ...

Pages