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A sum is considered certain when it can be made certain. By this, I take it, is meant where it can be determined by computation. ...

However, in each case, Royal Trust…reviewed the Trust document to ensure that the proposed approval was within its authority and then considered whether there were any negative consequences for the beneficiaries" (para. 34). ...

The principle of corporate non-consolidation, set out in para. 97 of Copthorne, requires that each corporation's tax liability be considered independently (para. 47). ...

Zhang as purported additional consideration for the transfer, a joint s. 85(1) election was filed and a rectification order was sought to have the share issue be considered to have occurred on the date of the transfer. ...

The funds are ultimately derived as consideration for the employee’s services, and on that basis they are properly to be considered emoluments or earnings. ...

Therefore, even if Adobe India is considered to be the Assessee’s PE, the entire income which could be brought in the net of tax in in the hands of the Assesee has already been so taxed in the hands of Adobe India … Thus…the facts in this case do not provide the AO any reason to believe that any part of the Assessee’s income has escaped assessment under the Act. ...

[I]t is for the referring court to ascertain whether, in the main proceedings, the NEC’s card processing service must be considered for VAT purposes to be a service which is ancillary to the sale of the tickets concerned or as a service ancillary to another principal service which is provided by the NEC to the purchasers of those tickets, which could be the reservation or the delivery of tickets for shows or other events and, therefore, forming with that principal service a single service with the result that that service must share the tax treatment of that principal service (see… Card Protection Plan … Case C‑349/96 …[and] Wojskowa Agencja Mieszkaniowa … Case C-42/14 …). ...

Canada (Attorney General), 2017 BCSC 209-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission no rectification of considered decision not to distribute trust income The petitioner was a personal trust, with another trust (“Alta Trust”) as its sole income and capital beneficiary. ...

By the 2009 MOC, students enrolled on the validated courses were to be "considered members of [MU]" but were not entitled to receive university student ID cards and access to university facilities and resources was very limited. ...

He then quoted the statement in Re Hetherington (deceased) [1990] Ch 1 that “even where a decision of a point of law in a particular sense was essential to an earlier decision of a superior court, but that superior court merely assumed the correctness of the law on a particular issue, a judge in a later case is not bound to hold that the law is decided in that sense,” and then concluded (at para. 8): It follows from those observations, and from the way in which the issue of RCF III as a taxable entity was considered in RCF III, that the view in RCF III that the partnership in that case was a taxable entity is not binding in these proceedings. ...