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Results 7741 - 7750 of 7915 for considered
TCC

Panda Realty Ltd. v. MNR, 86 DTC 1266, [1986] 1 CTC 2417 (TCC)

Many of these same authorities have very recently been considered and applied in Johns-Manville Canada Inc. v. ...
TCC

High-Crest Enterprises Limited v. The Queen, 2017 TCC 210, which replaces 2015 TCC 230, nullified on procedural grounds by 2017 FCA 88

Occupancy of the addition began in the first quarter of 2010. [5]               Pursuant to the Excise Tax Act, the Appellant is considered to have made a self-supply of the addition to the Springhill facility. ...
TCC

Abenaim v. The Queen, 2017 TCC 223

If the answer to that question is in the negative, then a sufficient nexus exists between the receipt and the loss of employment for the payment to be considered a retiring allowance. [103]   In this case, in light of the evidence, I am of the opinion that the entire amount [confidential] paid by the KM Group to Mr. ...
TCC

Fonds de solidarité des travailleurs du Québec (F.T.Q) v. The Queen, 2018 TCC 3, aff'd on s. 18(1)(a) grounds 2019 FCA 36

Evidently, the decisions of Canadian courts concerning these provisions must also be considered and applied. [33]   A gift contract is defined in article 1806 of the CCQ. ...
TCC

Montana Reclaimed Lumber Co. v. The Queen, 2018 TCC 51

The timing of the export is determined by subsection 5(1) of the SLPECA, which indicates that the wood is considered to have been exported at the time it was loaded aboard the truck conveying it to the Appellant’s premises in the United States. [56]   The Appellant submitted that taxation of the wood under the SLPECA was arbitrary since reclaimed softwood lumber products recovered in an exempt region and exported to the United States would not be subject to an export charge while reclaimed softwood lumber products recovered in a non-exempt region and exported to the United States would be subject to an export charge. ...
TCC

LBL Holdings Limited v. The Queen, 2018 TCC 63

The Queen, [4] Justice Jorré considered section 241. He held that, while section 241 is designed to protect taxpayer privacy, paragraph 241(3)(b) clearly allows the Minister to produce otherwise private taxpayer information if that information is relevant. ...
TCC

Chao v. The Queen, 2018 TCC 72 (Informal Procedure)

They read as follows: 10 The law shall be considered as always speaking, and where a matter or thing is expressed in the present tense, it shall be applied to the circumstances as they arise, so that effect may be given to the enactment according to its true spirit, intent and meaning.. . . 12 Every enactment is deemed remedial, and shall be given such fair, large and liberal construction and interpretation as best ensures the attainment of its objects. [90]   The question that may arise with respect to a particular legal requirement in certain factual circumstances is whether the maxim that “the law does not require the impossible” [39] has any application. ...
TCC

Lamontagne v. M.R.N., 2018 TCC 153

Both entities considered the Appellant’s status, and both ruled that the Appellant was self-employed. [4] [10]   The Appellant testified at the hearing of this appeal, while John Lanni, regional vice-president of Sun Life, and Jean Paquet, general manager of Sun Life’s Brossard Financial Centre during the year in dispute, testified on behalf of Sun Life. ...
TCC

Larose v. MNR, 92 DTC 2055, [1992] 2 CTC 2339, [1992] 1 CTC 2667

It was in '83 or later because, well, either the buildings are considered as effectively disposed of in '83 because they were sold at a judicial sale or were subject to givings in payment, or one could consider that the appellant, in '88, due to the judgment of the Court of Appeal, was entitled to the balance of the sale price. ...
TCC

Metrobec Inc. v. The Queen, 2018 TCC 115

There are many cases in which the matter has been considered both in this court and the Federal Court of Appeal. ...

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