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Results 7191 - 7200 of 7926 for considered
TCC

Jackman v. The Queen, 2022 TCC 73

It was also used to travel to, attend, and entertain at boat shows in British Columbia and Washington that the Jackmans considered key to their business and at which they rented booths for their marina. ...
TCC

Stroud v. The Queen, 2022 TCC 86 (Informal Procedure)

The following criteria should be considered: the profit and loss experience in past years, the taxpayer’s training, the taxpayer’s intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...
TCC

Lewisporte Holdings Ltd. v. R., [1999] 1 CTC 2056, 99 DTC 253, 1998 CanLII 185

On March 27, 1980, the Board of Directors of the Appellant considered a proposal from P.M. ...
TCC

Cooper v. R., [1999] 1 CTC 2312

The operative provisions of that indemnity reads as follows: Now Therefore be it Resolved That: (L504/R2742/T2/BT2) test_marked_paragraph_end (2074) 0.833 0489_6265_6377 I In consideration of their providing the Guarantees, the Corporation is hereby authorized to provide the following assurances to the Guarantors: (a) The Corporation shall agree to pay all of the costs of the Guarantors in connection with their entering into the Guarantees; (b) The Corporation shall agree to indemnify and save the Guarantors harmless from any claim, liability or loss arising in respect of the Guarantees, from time to time, including, without limiting the generality of the foregoing, any claims, liabilities or losses arising as a result of the Guarantors having to honour their obligations under the Guarantee; and (c) in the event that any of the Guarantors are required to pay any amount in respect of the Guarantees, then to the extent of such payment, the Corporation acknowledges and agrees that the Guarantors will be entitled to an assignment of the Loan as if the Guarantors had been original parties thereto, and for the purposes of this provision, any amounts owing by the Corporation to the Guarantors, and unpaid, including amounts owing by the Corporation to the Guarantors under paragraph (a) or (b) above, shall be considered payments made by the Guarantors. ...
TCC

Hak v. R., [1999] 1 CTC 2633, 99 DTC 36

This subsection illustrates a style of legislative drafting that started with tax reform in 1972 in which the drafter of the Act considered it clever to reduce complex algebraic or mathematical formulae to a single page-long sentence. ...
TCC

Larsen v. R., [1998] 4 CTC 2049, 98 DTC 2193

During this period he only considered the timber which was of a butt diameter of 12 inches or more. ...
TCC

Johnston v. R., [1998] 4 CTC 2437

Although the Reply to the Notice of Appeal posed a question as to whether, in the alternative, the expenses claimed were reasonable in the circumstances, no submission was made by Respondent’s counsel in that regard and, accordingly, will not be considered in these Reasons. ...
TCC

Markovzki v. R., [1998] 4 CTC 2481, 98 DTC 2040

It is the GMS arrangement alone which must be considered. Also, while the relationship between the plaintiff and Marlo we-Yeoman may have been created by contract, it was not an agency contract. ...
TCC

Henning v. K., [1998] 4 CTC 2692

The appellant further submits, in the alternative, that if he were to be considered a director of Affordable, he exercised the degree of care, diligence and skill to prevent Affordable’s failure to remit source deductions that a reasonably prudent person would have exercised in comparable circumstances. ...
TCC

Stewart v. R., [1999] 4 CTC 2091 (Informal Procedure)

Subsection 118.4(1) defines the nature of an impairment in the following terms: 118.4(1) For the purposes of subsection 6(16), sections 118.2 and 118.3 and this subsection, (a) an impairment is prolonged where it has lasted, or can reasonably be expected to last, for a continuous period of at least 12 months; (b) an individual’s ability to perform a basic activity of daily living is markedly restricted only where all or substantially all of the time, even with therapy and the use of appropriate devices and medication, the individual is blind or is unable (or requires an inordinate amount of time) to perform a basic activity of daily living; (c) a basic activity of daily living in relation to an individual means (i) perceiving, thinking and remembering, (ii) feeding and dressing oneself, (iii) speaking so as to be understood, in a quiet setting, by another person familiar with the individual, (iv) hearing so as to understand, in a quiet setting, another person familiar with the individual, (v) eliminating (bowel or bladder functions), or (vi) walking; and (d) for greater certainty, no other activity, including working, housekeeping or a social or recreational activity, shall be considered as a basic activity of daily living. ...

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