Search - considered
Results 12611 - 12620 of 49528 for considered
T Rev B decision
Verne K Olson v. Minister of National Revenue, [1978] CTC 2625, [1978] DTC 1439
Some of them would last a year or two and in that time, if all repairs were considered to have been done, they may have been replaced one and one-half times. ... He continued that it was not within the scope of paragraph 18(1)(b), but rather, that expenditure should be approached and considered in the same fashion as the Exchequer or Federal Court approached similar expenses in several cases. ... He did not suggest that those cases were the same as or similar to this appeal, but rather submitted that when the issue in this appeal was being considered, the same consideration should exist as those cases set forth. ...
SCC
J. B. McLeod v. City of Windsor, [1917-27] CTC 141
Act, have been considered in many cases, and as Lord Moulton says in Cotton v. ... It was considered in a case of Re Gibson, 48 D.L.R. 428, and there it was held by Mulock, C.J. ... There is also to be considered in this appeal the declaratory action instituted by the appellant to have the assessment declared illegal and also unconstitutional. ...
MBCA decision
Rural Municipality of St. Vital v. City of Winnipeg, [1945] CTC 19
In a considered judgment he held ([1944] 2 W.W.R. 217) that the land in question is a public park notwithstanding that golf is played thereon and playing fees are required to be paid. ... No authority was cited in support of the first of these contentions, and I have not been able to find any reported case in which this point has been considered. ... The point which I think vital in this case was apparently not raised—at least was not considered. ...
EC decision
D. R. Fraser & Company, Limited v. Minister of National Revenue, [1945] CTC 429
So far as I am aware there are no reported Canadian cases where the principles applicable to an extractive industry have been fully considered. ... A note by the learned editor in the first volume of Saunders’ Reports, p. 27 7 c, puts the matter thus: ‘The principle of these decisions appears to be this: that wherever at the time of the contract it is contemplated that the purchaser should derive a benefit from the further growth of the thing sold, from further vegetation and from the nutriment afforded by the land, the contract is to be considered as for the interest in the land; but where the process of vegetation is over, or the parties agree that the thing sold shall be immediately withdrawn from the land, the land is to be considered as a mere warehouse of the thing sold and the contract is for goods.’ ... Green (supra) it was said: "‘Lastly, in determining the effect of such a contract at law the effect of the Sale of Goods Act, 1893, has now to be considered. ...
FCA
Canada v. Hirschfield, 2025 FCA 17
Those regulations, part of the scheme governing the set of veterans benefits put in place in 2006, expressly state that only non-economic compensation is to be considered in calculating the statutory offset. [36] The letter from VAC to Mr. ... Hirschfield considered was an individual action. He did not refer to the availability of relief through the VRAB, or explain his decision not to pursue the remedies available in that forum. ... It then considered whether the claim for aggravated and punitive damages affected the correctness of that conclusion. ...
TCC
Toews v. The King, 2025 TCC 123 (Informal Procedure)
The term “gifting arrangement” is defined in paragraph (b) of the definition of such term in subsection 237.1(1), to include any arrangement under which it may reasonably be considered, having regard to statements or representations made in connection with the arrangement, that if a person were to enter into the arrangement, the person would incur a limited recourse debt, determined under subsection 143.2(6.1), that can reasonably be considered to relate to a gift to a qualified donee. [28] Subsection 143.2(6.1) defines limited recourse debt with reference to the term “limited recourse amount”. Under subsection 143.2(6.1) the limited recourse debt in respect of a gift is the total of certain amounts, at the time a gift is made, including each “limited recourse amount” of the taxpayer and certain other specified parties, that can reasonably be considered to relate to the gift. ... In Hexalog Ltée c R 2005 TCC 67, the Court considered the phrase “in respect of” in section 237.1 and concluded that “consideration” should be interpreted broadly to include all amounts received from investors of a tax shelter. [84] I agree. ...
TCC
Gill v. M.N.R., 2006 TCC 149
Some were considered as full-time workers and were paid an hourly wage. ... Some varieties – such as Blue Crop – are considered to be high-yielding plants. ... Turgeon’s notes indicate she considered Rajinder had done most of the talking. ...
Technical Interpretation - Internal
5 May 1998 Internal T.I. 9812220 - FIRST NATIONS WORKSHOP - INDIAN TAXATION
Salary and wages were, in the Bulletin, considered to be earned where the services were performed. ... In summary, salary and wages were considered, until 1983, to be earned where the services were performed. ... First Nations that do not meet these requirements can be considered on a case-by-case basis. ...
Technical Interpretation - External
27 August 2012 External T.I. 2012-0438001E5 - Taxable Benefits – Employer-Provided Vehicles
Generally, any location at or from which the employee regularly reports for work or performs the duties of employment, may be considered a RPE for the employee. ... In such instances, travel between an employee's home and his or her RPE would be considered personal travel and would give rise to a taxable benefit where the employer pays for or provides a vehicle for such travel. ... However, employer-provided transportation relating to an employee's travel between their temporary residence (e.g. a hotel) and a special work site that is considered a RPE for the employee would be considered personal in nature and would give rise to a taxable benefit under paragraph 6(1)(a) of the Act. ...
Technical Interpretation - External
16 January 2017 External T.I. 2016-0655701E5 - Article 5(3) - Demolition
Two contracts may be considered a single unit if they form a coherent whole commercially and geographically but this can only be determined on a case by case basis after reviewing all relevant information. ... The two issues that you asked us to address is: (1) whether such decommissioning work (the First Segment and the Second Segment) can be considered to fall under the scope of the Construction PE Provision; and (2) whether the twelve month test (“Duration Test”) in Article 5(3) of the Model Treaty can be considered to apply in this situation. ... (footnote 1) Therefore, even though the Commentary does not specify that demolition would be considered a construction or installation project or that a site where demolition takes place would be considered a building site, it is our opinion that the decommissioning work described above (both the First Segment and the Second Segment) would likely be considered to fall under the scope of the Construction PE Provision. 2. ...