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Results 12531 - 12540 of 49528 for considered
TCC
Demont v. The Queen, docket 2001-3593-IT-I (Informal Procedure)
He considered the Ornish Program to be radical. They did not come across any other program that dealt with the three aspects of the problem as did the Ornish Program. [24] When they discussed his wife's problems with Dr. ... Ornish's clinic and they considered alternatives. She talked to Dr. ... This change in her medical condition was brought about by her attendance at the clinic. [76] The Court has considered carefully all of the cases referred to by both counsel and has already referred to them in the recitation of facts found by the Court during the trial. ...
TCC
Hyswick v. M.N.R., docket 2002-721(EI)
He attended one conference concerning bylaw enforcement but had considered himself to be ineligible to attend conferences of municipal workers because he was not an employee of the City. ... Later, he continued with the City and had never been considered by either municipality as other than an independent contractor. ... Judge Porter also found the workers considered themselves as professionals- able to choose whether or not to work for clients- and held that the relevant worker/interpreter was not "enveloped into the business of the Appellant, but was retained as an outsider to provide services to their clientele. ...
TCC
Technical Service Solutions Inc. v. M.N.R., docket 2000-3366(EI)
If, however, little or no control is exercised and the individual is reasonably free to determine when and how the work is performed, he will generally be considered to be an independent contractor. ... If an individual stands to lose from the relationship, he will generally be considered to be an independent contractor. ... If however, the work is ancillary to the business, the individual will generally be considered to be an independent contractor. [64] The Federal Court of Appeal in Moose Jaw Kinsman Flying Fins v. ...
TCC
Newell v. The Queen, 2010 TCC 196 (Informal Procedure)
Evidence [6] It was agreed that evidence given in one cause would be considered to apply to the other, where applicable. [7] Gary Newell testified that he was a miner-prospector. ... This is not purely subjective but objective factors must be considered. ... He has not met the standards of businesslike behaviour. [104] It is true that he incurred substantial expenses, but this has already been considered by Parliament in allowing those expenses before it became a business (even though reasonable expectation of profit was not necessary). [105] For purposes of the G.S.T. requirements, he has not met the indicia of commercial activity test. ...
TCC
Boily v. The Queen, 2007 TCC 603 (Informal Procedure)
" As previously stated, RV could invest the proceeds of the sale of B shares as it saw fit, even if the CRA considered the funds held in a locked-in/self-directed RRSP used to acquire an investment in RV were security for the loan granted to Mario Boily. ... He claimed that in such a case, under subsection 146(12) of the Act: (i) the plan is no longer considered an RRSP. The Agent for the Appellant explained that, from that time on, all the property of the RRSP is considered to have been subject to a disposition in exchange for consideration equal to its FMV and the annuitant is therefore deemed to have acquired it at a cost equal to its FMV at the time. ...
TCC
Groupe TVA Inc. v. The Queen, 2008 TCC 509
Freud, [1969] S.C.R. 75 is to the effect that if the guarantee is speculative, it cannot be considered a capital expense; iii) The Queen v. ... Ltd., supra, decided that the situation must be considered from the point of view of the businessperson who makes the decision to grant the guarantee ... Fleury’s testimony revealed that the future interest in the net profit generated by the film was in no way an element considered by TM in its decision to grant the bond as it knew that the chances of a Quebec film being profitable at the time were practically non-existent. ...
TCC
BLAJ Hospitality Inc. v. M.N.R., 2008 TCC 398
All revenues are deposited in BLAJ’s bank account but a report is printed daily showing the amount of tips each server received during his or her work shift, for they are not considered as revenues by BLAJ ... (Can.), [1986] 1 S.C.R. 678, considered the meaning of “insurable earnings” and determined that the term “r emuneration” was broad enough to encompass gratuities paid by a customer and then distributed by the employer to its employees. ... It is worth reproducing his full analysis. 55 There are two contextual aspects regarding the subject provisions that must be considered. ...
TCC
North Star/Fairmont Plating Ltd. v. MNR, 2003 TCC 477
., (supra), the Federal Court of Appeal laid out certain matters which should be considered by this Court when hearing these appeals. ... Again, the Minister failed to take into account this matter of vacation time, except to the extent that if an emergency arose, Santos would have to return from vacation (item (ee)). [35] Another duty he took on, which Santos considered a regular salaried general manager would not, was to check the electroplating tank at night. ... The significance of this was unknown to the Minister and was not considered by him. ...
TCC
Transocean Offshore Limited v. The Queen, 2004 TCC 454
For tax purposes, damages or compensation received, either pursuant to a court judgment or an out-of-court settlement, may be considered as on account of income, capital, or windfall to the recipient. ... However, compensation on account of capital may be taxable if it is considered as [an] "eligible capital amount", or if there is a "disposition" of a "property" where the payment is made in exchange for the discharge of a legal right. ... Com., 41-1 USTC 255, which is to the effect that to determine whether, and to what extent, an amount received as damages, whether by compromise or as a result of a judgment, should be considered income, it is necessary to look at the nature of the item for which those damages are a substitute. ...
TCC
Criterion Capital Corporation v. The Queen, docket 1999-4603-IT-G
The Wiebe Door case really involves two tests, both of which are to be considered. ... In deciding whether the services of Criterion could reasonably be regarded as services of an officer or employee, the services that are provided by Douglas Mason, as President and a director, cannot be considered. ... Judge Mogan considered it a relevant criteria in deciding that the services provided by Mr. ...