Search - considered

., [2] the relevant factors the Court considered were that the couple sold their Ottawa home and that they moved into an Ottawa apartment, expecting an imminent posting overseas by a company of consulting engineers, Triple M. ...

Counsel for the appellant argued that at “common law”, [3] debt settlement gains were considered to be capital gains unless they related to income obligations incurred in the same year as the settlement itself. ...

The secondary issue will be considered later in these reasons. The appellants are lawyers who practise together in a small partnership. ...

Even as one of a number of factors or tests to be considered, as suggested by Chief Justice Bowman in Freeway Technologies, intentions cannot be given weight in circumstances such as this. ...

In Black’s Law Dictionary, “goodwill” is defined as:   A business’s reputation, patronage, and other in tangible assets that are considered when appraising the business, esp. for purchase; the ability to earn income in excess of the income that would be expected from the business viewed as a mere collection of assets ...

I have considered whether on that basis it could be said that section 7 did not apply to the acquisition of the disputed shares but I have concluded that it did so apply because the granting of the options to the appellant was based on his status or position with Granville and Jantar. ...

The validity of this limiting provision was considered and accepted by the Supreme Court of Canada in 1977 in the Smerchanski [2] decision: Since it is not contested that a taxpayer may validly waive his rights of appeal against a tax assessment and that no question of public policy is involved to preclude such a waiver, the only issue of importance in this appeal is whether the tax authorities, seriously contemplating prosecution, and by indictment as in the present case, are entitled to exact a waiver of rights of appeal as a binding term of settling a clear tax liability when overtures for settlement are made by the taxpayer and, in consequence, to abandon their intention to prosecute. ...

Bowie J. found: The English version of the Act was ambiguous regarding what was considered attendance. ...

The management of the appellant therefore considered expansion by franchising. ...

I should note that, with respect to the real estate transactions, the very issue of their taxability was considered by Judge Hyde. ...