Search - considered

Results 5221 - 5230 of 7927 for considered
TCC

Marilake Education Centre Inc. v. M.N.R., 2013 TCC 82

As noted in Royal Winnipeg Ballet at para. 64, the relevant factors must be considered "in the light of" the parties' intent. ... Chow's evidence, it became clear that the appellant considered the contract of little importance. ...
TCC

Desroches v. The Queen, 2013 TCC 81

She even said that she considered the appellant to be her father and that she had never seen him take or sell drugs. ... The Queen, 2005 TCC 330, Justice Archambault once more considered the Quebec evidence law applicable to an extrajudicial admission, and nowhere in his decision did he discuss the requirement, to allege the extrajudicial admission in the pleadings. ...
TCC

École de langues ABCE inc. v. M.N.R., 2012 TCC 410

He considered himself to be an employee of the École de Jonquière.   [27]         At that point, Mr.  ...   [51]         In Wiebe Door, Justice MacGuigan examined the four case law tests to be considered in determining whether a contract is one of service or for the provision of services. ...
TCC

Belcourt Properties Inc. v. The Queen, 2014 TCC 316

The Appellant as such considered that the Notice of reassessment under appeal entailed an overall disputed tax debt that exceeded the amount of $150,000 referred to in Schedule II of the Tax Court of Canada Rules (General Procedures [sic]) being a minimum of $467,786 in the aggregate (being, the tax liability under Part I in the amount of $46,810 and under Part III in the amount of $420,952); 8.       ... Consumers’ Gas Co., [1987] 2 F.C. 60, [1987] 1 C.T.C. 79, the total amount in issue is not the amounts that were considered or determined in the process but rather the final product of the process. [29]         Here, the Part III tax was the object of a proposed assessment only, and even though it had been the object of a determination by the Minister, it was not at issue in the appeal before me, which appeal was filed pursuant to subsection 169 of the ITA against the assessment issued for the 2005 taxation year. ...
TCC

McLeod v. The Queen, 2017 TCC 192

It is clear from both Day’s evidence that he considered McLeod and Mongos as interchangeable as did McLeod who kept insisting he was the director and shareholder of Mongo’s when posed questions that challenged Mongo’s entitlement to any management service fees. ... While proceeds of sale clearly work into the calculation of profits due to recapture of depreciation, sale of good will etc., there was no indication the proceeds of sale were considered profits in their entirely. ...
TCC

Dingman v. The Queen, 2017 TCC 206

The Dannea’s fees for this service was a 7% fee. [11]          The funds withdrawn from the Dannea’s bank account in any given year, were considered to be loans to the appellant as evidenced by a promissory note dated December 31 of the given year. ... In my opinion, it is a benefit conferred on the shareholder of the corporation which was rightly assessed by the Minister pursuant to subsection 15(1) of the Act. [37]          The appellant alleged that the amount of $12,173.75 should have been considered as a deductible business expense but he did not explain what he has done with the money. ...
TCC

Hokhold v. The Queen, 2017 TCC 217, aff'd 2018 FCA 163

The question of when a debt is to be considered uncollectible is a matter of the taxpayer’s own judgment as a prudent businessman. ... Fisher described how this determination should be made: For the purposes of the Income Tax Act, therefore, a bad debt may be designated as the whole or a portion of a debt which the creditor, after having personally considered the relevant factors mentioned above in so far as they are applicable to each particular debt, honestly  and reasonably determines to be uncollectable at the end  of the fiscal year when the determination is required to be made, notwithstanding that subsequent events may transpire under which the debt, or any portion of it, may in fact, be collected. ...
TCC

Barbour v. The Queen, 2018 TCC 77 (Informal Procedure)

It stated in part that CCA grants were considered taxable income and T4A forms would be issued in respect thereof. [8]   The Appellant testified that she had a business called “b.h. ... (as he then was) considered a somewhat analogous situation in which the taxpayer, a professor on sabbatical, claimed expenses as being on business account. ...
TCC

Clermont v. The Queen, 2017 TCC 32 (Informal Procedure)

She therefore arrived at total revenues of $280,530 ($264,654 + $15,876) for this harvest. [30]   Because, according to the police investigation, the appellant, his brother Mario and his nephew Patrick were considered business partners, each was assessed for taxes to be recovered on all of the supplies, given their solidary liability for the payment of the taxes. [31]   The ARQ registered the appellant under the ETA as of December 1, 2013. ... She had considered only the revenues from a single harvest, counting the minimum of 2.5 ounces of buds per plant, at the average price that Ms.  ...
TCC

Leblanc v. The Queen, 2008 TCC 7 (Informal Procedure)

The problem has often been considered in actions brought under s. 4(1)(e)(i) of the Divorce Act and, generally speaking, a finding that the parties were living separate and apart from each other has been made where the following circumstances were present:   (i)         Spouses occupying separate bedrooms. ... Reference to these seven factors will prevent an inappropriate emphasis on one factor to the exclusion of others and ensure that all relevant factors are considered. ...

Pages