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Results 6061 - 6070 of 7915 for considered
TCC
Lichtman v. The Queen, 2017 TCC 252 (Informal Procedure)
His curriculum vitae clearly shows that he possesses the academic training, experience, publications, teaching and lecturing to be considered an expert in the laws and practices of Orthodox Judaism. ... It provides guidance in all areas of life and is considered to be binding by Orthodox Jews. ... Since it offers a dual curriculum to students, VHA could be considered a place of academic and religious instruction but it cannot be characterized as a place of religious worship. ...
TCC
David Ludmer, Brian Ludmer, Cindy Ludmer and Ludco Enterprises Ltd. v. Minister of National Revenue, [1993] 2 CTC 2494, 93 DTC 1351
And it's considered relatively safe, but on the other hand you get relatively low returns. ... Gutenplan considered these token dividends because the amount, in his view, was very small. ... And was that a factor which also, or that you also considered in making the decision to invest? ...
TCC
CAE Inc. v. The Queen, 2011 DTC 1362 [at at 2031], 2011 TCC 354, aff'd 2013 DTC 5084 [at 5944], 2013 FCA 92
In other cases, the appellant sold simulators and the respondent considered those sales as giving rise to business income, while the appellant considers the sales as giving rise to capital gains ... [45] The issue concerning the simulators being presently considered is whether the sale to BAL gave rise to income or to a capital gain. ... The more closely a taxpayer's business or occupation is related to real estate transactions, the more likely it is that the income will be considered business income rather than capital gain. ...
TCC
722540 Ontario Inc. v. The Queen, 2002 DTC 1307 (TCC)
In Mark Resources, Bowman J. considered whether this provision applied to the facts before him, and he concluded that it did not. ... Central Supply Company (1972) Limited et al. [36] In those decisions, the Court of Appeal has set out the following three factors that are to be considered in the application of subsection 245(1). ... It was considered and rejected by Strayer J.A. in Fording Coal [40], and more recently by Rothstein J.A. in OSFC. [41] The answer to the first question is "yes". are the transactions in accordance with normal business practice? ...
TCC
9101-2310 Québec Inc. v. The Queen, 2013 DTC 1136 [at at 711], 2012 TCC 365, rev'd 2013 FCA 241
In reaching this conclusion, I have also considered the wide words “or by any other means whatsoever, ” but I think that they are directed to the means or procedure by which transfers may be accomplished, rather than to the scope of the expression “has transferred property” and that they do not expand that scope beyond the natural meaning of the expression. ... No all-inclusive statement can be made as to when a loan can be considered to be ‘genuine’, but a written and signed acknowledgment of the loan by the borrower and agreement to repay it within a reasonable time ordinarily is acceptable evidence that it was so. ... ] [79] In all three cases, Les boutiques San Francisco, Yachting & Sports Pigeon inc. [37] and 9083-4185 Québec inc., the parties were unsuccessful in their claims of ownership but were nonetheless considered creditors ...
TCC
Chow v. The Queen, 2001 DTC 164 (TCC)
She considered him to be an experienced businessman and restaurant owner. ... There were many things that the Appellant could have done, but he did nothing. [133] The same situation was considered by this Court in Bains v. ... Counsel for the Appellant argued that he should be considered an "outside director" from the point of view of the Company's finances and accounting. ...
TCC
The Canadian Medical Protective Association v. The Queen, 2008 TCC 33, [2008] GSTC 88, aff'd supra
Exceptions to external management may be considered where cost/benefit analysis indicates a positive return to the Association. ... The performance of the portion of the Fund that is passively managed will be considered satisfactory if the tracking error from the associated index is in the range of plus or minus 10 basis points. ... This provision has been considered only twice by this Court, and neither case sheds any light on the meaning of the expression "any administrative service" ("les services administratifs"). ...
TCC
Guindon v. The Queen, 2012 TCC 287, rev'd infra
In Wigglesworth, the Supreme Court considered the application of the legal rights enumerated in section 11 of the Charter to non-criminal proceedings. ... Responding to this submission, the Appellant puts forward two alternative arguments to be considered should this Court find the Appellant liable pursuant to section 163.2 of the Act ... Both situations (either knowing a statement was false or engaging in culpable conduct) must be considered in relation to the same time frame because there is nothing to indicate that it should be otherwise ...
TCC
Fagan v. The Queen, 2012 DTC 1139 [at at 3217], 2011 TCC 523
Holmes had different intentions concerning the scope of the waiver, Justice Miller considered how the reference in the waiver to “Canadian Exploration and Development Expense” should be interpreted objectively. ... H.M. [95 DTC 5311] this Court considered earlier jurisprudence and confirmed the basic principle that it is the duty of the Minister to assess, and if necessary reassess, taxpayers' returns so as to apply correctly the law to the facts. ... The facts of this case indicate that the Minister examined the information of Sierra Trinity Inc., which is the corporation that carried out the operations of the joint venture, and considered whether the expenses were permissible. 991 had no separate expenses from those of the joint venture ...
TCC
Klotz v. The Queen, 2004 DTC 2236, 2004 TCC 147, aff'd 2005 DTC 5279, 2005 FCA 158
He considered that what she did was naïve but that it did not in his view compromise the conclusion. ... Laverty considered three approaches to value: income, cost and market data. ... He chose not to ignore it (96 DTC 1609-1610) but considered all of the appraisals and arrived at a figure that differed from all of them. [43] Neither case is of much assistance here. ...