Search - considered
Results 12581 - 12590 of 49528 for considered
FCTD
Seaspan International Ltd. v. Her Majesty the Queen, [1993] 2 CTC 307
The definition of vehicle in the context of the Excise Tax Act has been considered in Westar Mining, supra. ... The word is commonly understood as something which moves or runs on the land, not something which flies in the air, although etymologically the term might be considered as broad enough to convey a conveyance propelled in the air.” ... A boat or a ship is used to carry or convey persons or objects, therefore it can be considered to be a vehicle for purposes of this section of the Act. ...
TCC
Robert Verrier & Fils Ltée v. Minister of National Revenue, [1992] 2 CTC 2464, 92 DTC 2354
The fact that the commission on a car insurance premium is only 12.5 per cent also has to be considered. ... & V. transaction, it was considered that a greater portion of customers would easily agree to renew their contracts. ... The precarious financial situation of the vendor cannot necessarily be considered as a negative indicator. ...
TCC
Robert Moysey v. Her Majesty the Queen, [1992] 2 CTC 2657, 92 DTC 1861
The debtor is considered to have disposed of the property for the principal amount of his indebtedness that is extinguished as a result of the creditor's acquisition or reacquisition of the property. ... Legislative history of section 80 The only provisions in section 80 that need to be considered for our present purposes are those found in subsections (1) and(4) of this section. ... It should not be overlooked that the deeming provision in subsection 80(4), that interest payable shall be considered as a principal amount, does not apply for the purposes of section 79 of the Act but applies only for the purposes of subsections 80(1) and 80(3) of the Act. ...
TCC
Cassidy's Limited (Formerly Packer Floor Coverings Ltd.) v. Minister of National Revenue, [1990] 1 CTC 2043
O'Hanley and the Imbrex controller reviewed the account of a supplier which yielded Packer a gross profit of 11 per cent which was considered low; Mr. ... The Supreme Court of New Zealand considered a case where a company deducted losses incurred by theft by a senior employee in computing its income: W.G. ... The amounts defalcated were considered by Packer to be a cost of goods. ...
TCC
Mark Harding v. Minister of National Revenue, [1990] 1 CTC 2322, 90 DTC 1169
The third factor considered by Dr. Schoney was the reasonable expectation of profit. ... The third scenario considered is based on Chianina prices maintaining their 1980 levels, neither increasing in 1981 and 1982 nor decreasing in subsequent years. ... Schoney's report implies that the appellant considered various scenarios, the probability of the occurrence of any of them and made his plans and estimates on that basis. ...
TCC
Alexander Orr v. Minister of National Revenue, [1989] 2 CTC 2348, 89 DTC 557
The matter of seeking relief from, the provisions of the Income Tax Act may be considered in three areas: tax evasion, tax avoidance and tax planning. ... In that case the Court reviewed not only the Canadian jurisprudence but also considered cases from the United Kingdom, the United States and Australia. ... Tax avoidance may best be considered as a grey area between tax evasion and tax planning. ...
FCTD
The Saugeen Indian Band, as Represented by Its Chief, Vernon Roote, and by Its Councillors, Arnold Solomon, Roy Wesley, Oliver Kahgee Sr., Chesley Ritchie, Mildred Ritchie, Harriet Kewaquom, Marie Mason, and Franklin Shawbedees v. Her Majesty the Queen, [1989] 1 CTC 86, 89 DTC 5010
If the tax is likely to be recouped only because, like other expenses, it is a cost of doing business, then it is not considered to be indirect for constitutional purposes (see Hogg, Constitutional Law of Canada, 2nd ed. 1985, pages 604-9). Counsel for the plaintiff argues that, similarly, indirect taxes which cling to a commodity should be considered as falling within section 87 while those which are recouped only as a general cost of doing business should not. ... The argument that Parliament considered it unnecessary to expressly provide for a conditional exemption in the Excise Tax Act because it considered that such exemption already existed by virtue of the operation of section 87 of the Indian Act is a difficult one to accept. ...
TCC
Barbara Joan Rodgers and 493800 Ontario Limited v. Minister of National Revenue, [1989] 1 CTC 2181, 89 DTC 78
In arriving at the above opinion of value the following points were considered to be determinant: 1. ... So, to this point, it is my view the appellant has not proved that there were adequate real assets to support the shareholders' position; and the restriction on transfer of the shares must be considered as a major disadvantage. ... I am satisfied that the salient fact regarding the transfer restrictions on the shares was known to all relevant parties at the date of issue, and would have been “considered by a reasonable and objective observer". ...
FCTD
Esso Resources Canada Limited v. Her Majesty the Queen, [1988] 2 CTC 312, 88 DTC 6469
The determination of whether the plaintiff had such a right must be considered in reference to paragraph 43(c) of the Interpretation Act, R.S.C. 1985, c. 1-21. ... At the time of the repeal, all the procedure under s. 3A and s. 3B had been followed, and it can properly be said that the stage had been reached when the lessee could expect and was entitled to have the petitions and cross-petition considered in due course by the Governor in Council and to have a decision reached. ... In their Lordships' view, the entitlement of the lessee in the period prior to Apr. 9 to have the petitions and cross-petition considered was not such a "right". ...
TCC
Doris J. Neville v. Minister of National Revenue, [1988] 2 CTC 2201, 88 DTC 1546
This particular course is one strongly recommended by Real Estate Brokers and Managers, and is considered beneficial for increased production. ... Neville considered herself a "student" for the courses she was taking attempting to deduct, the amount there was understandable. ... As I have noted in other judgments, I find it somewhat difficult to relegate the end result of profitability to a minor position in the hierarchy of factors to be considered, in a determination of “chief source”. ...