Search - considered

Subparagraph a) [5] means, therefore, that in the application of the Convention (that is, where there is a conflict between the laws of the two States) it is considered that the residence is that place where the individual owns or possesses a home; this home must be permanent, that is to say, the individual must have arranged and retained it for his permanent use as opposed to staying at a particular place under such conditions that it is evident that the stay is intended to be of short duration. 13.    ... Subparagraph a) means, therefore, that in the application of the Convention (that is, where there is a conflict between the laws of the two States) it is considered that the residence is that place where the individual owns or possesses a home; this home must be permanent, that is to say, the individual must have arranged and retained it for his permanent use as opposed to staying at a particular place under such conditions that it is evident that the stay is intended to be of short duration. 13.    ...

        [9]      Presumably since Towers Perrin considered that it was prohibited under the Pension Benefits Act from paying the full formula amount to Mr.  ...   [15]     The matter has been considered on a number of occasions in the courts. ...

Rhyannon Martin, an experienced claims examiner for Aviva, testified that a move from claims examiner to independent adjuster would be considered a "lateral move" where an employee wanted more flexibility respecting hours and work location. ... As already mentioned, the Minister assumed in support of his decision the existence of a number of facts obtained by inquiry from workers and the business he considered to be the employer. ...

RECONCILIATION OF THE NET WORTH STATEMENT FOR THE PERIOD FROM JANUARY 1, 1996, TO DECEMBER 31, 1999   1999 1998 1997 1996 Net value at the end $550,876.00 $522,518.00 $458,936.00 $400,682.00 Net value in the beginning   $522,518.00 $458,936.00 $400,682.00 $344,406.00 Increase in net value     $28,358.00 $63,582.00 $58,254.00 $56,276.00 ADD         Personal expenses $10,000.00 $10,000.00 $10,000.00 $10,000.00 Federal income tax $5,251.00       Provincial income tax $5,000.00       Quebec pension plan $1,504.00         $21,755.00 $10,000.00 $10,000.00 $10,000.00 Total increase     $50,113.00 $73,582.00 $68,254.00 $66,276.00 DEDUCT         Taxable sources         Total declared income of Hope Coulombe $606.00 $2,951.00 $1,250.00 $863.00 Total declared income of Lloyd Stutervant $18,479.00 $52,246.00 $29,666.00 $29,790.00 Taxable dividend gross-up         Taxable dividend gross-up of Hope Coulombe  -$481.00-$250.00-$3,277.00 Taxable dividend gross-up of Lloyd Sturtervant  -$4,327.00-$4,750.00-$172.00   $19,085.00 $50,389.00 $25,916.00 $27,204.00   Non-taxable sources         Capital dividend   $23,193.00     Exempt capital gain from the residence $11,000.00       Non-taxable portion of capital gain $4,750.00       Inheritance from his mother     $25,000.00 $25,000.00   $15,750.00 $23,193.00 $25,000.00 $25,000.00 Total reductions $34,835.00 $73,582.00 $50,916.00 $52,204.00 Actual unexplained difference in net worth   $15,278.00 0.00 $17,338.00 $14,072.00 Elements not considered by CRA         Capital cost of depreciable property disposed of at the auction of April 24, 1999 (Appendix attached)   $92,584.00       Inheritance from his mother, the documents for which  are difficult to obtain $50,000.00         $142,584.00 0.00 0.00 0.00 Difference in net worth calculated by CRA   $157,862.00 0.00 $17,338.00 $14,072.00 In summary, CRA taxes the property that was acquired before the period and disposed of during the period as well as the inheritance from his mother.     ... The Appellant traded these in when the Company made purchases in 1990, so they cannot be considered part of the Appellant's assets at 1995 year end. ...

This amount was set up as a loan to Proma but it repaid no amount of the loan. 105 was considered to be head of the group of companies or the tip of the pyramid and it made more sense to set up the loan from the bank through this corporate entity. 105 also loaned money to other companies in the Metal Group as can be seen from the document in Exhibit A-1 at Tab 12. ... They were considered to be loans by the Appellant. They were booked by the accountants as loans and they were listed in the company's books for accounting purposes as loans. ...

Any and all incidences [sic] of solicitation or forms of solicitation of a Teach & Embrace Corporation client during the timeframe of this contract will be considered a breach of contract causing damages to the "Corporation" equivalent to the value of the business in progress with said client; moreover, over and above the current value of the said business in progress, damages equivalent to one‑hundred [sic] dollars ($100) per day for the length of the breach of contract will be claimed of the "Tutor" who contravenes the stipulations herein of non‑competition. ... Preparation and travel time is at your own expense (and is considered an allowable expense). ·    If you are invoicing for one‑on‑one tutoring done in a client's home, please ensure that a parent or legal guardian has signed the attendance sheet. ...

The letter stated that no request for interest relief because of financial difficulties or for other reasons would be considered under the fairness provisions for those years if the request was not made by the Appellant before January 1, 2005 (see also Exhibit I-12). ... Reducing taxes cannot in itself be considered a business for the purposes of the Act (see Moloney v. ...

The appellant said that he considered the $9,000 a loan but his accountant would need to be consulted to find out the true nature of the amount. However, as mentioned previously, the accountant considered the amount in question to be income. [15]     With no income during the years at issue, the appellant is essentially claiming that he and his spouse, Ms. ...

According to the MRQ's anti-tax evasion office, H.P. was considered an "accommodator. ... Sorm Han had been found guilty ex parte of criminal offences committed between December 1995 and November 1996, involving input tax credits that had been claimed illegally. [35]     The Minister's auditor indicated that the assessments at issue had been made on the following basis: the deduction for any amounts paid to the three subcontractors by Vêtements Zurek were disallowed, because these three subcontractors were considered "accommodators," and it was thought that their invoices were false invoices. ...

In this respect, the evidence essentially constitutes the self-serving testimony of Gérard Pelchat. [57]     The transfer was not something spontaneous and ill-considered, carried out without reflection. On the contrary, the transfer was the result of a considered and self-serving decision. ...