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Results 13021 - 13030 of 49499 for considered
FCTD
Ghermezian v. Canada (Attorney General), 2020 FC 1137
However, as with other aspects of administrative decision-making, there may be cases in which the administrative decision maker has not explicitly considered the meaning of a relevant provision in its reasons. ... In other words, there is no express indication that the decision-maker considered the possible application of ss 231.2(2) and (3) and whether judicial authorization should be sought before issuing the RFIs. ... I find no basis to conclude that the breadth of the Gherfam RFI renders it unreasonable. [155] I have also considered the Applicant’s arguments that the trusts that are the subject of the investigation pursued through the Gherfam RFI are not within the Minister’s jurisdiction. ...
EC decision
Pure. Spring Company Limited v. Minister of National Revenue, [1946] CTC 169
Arlidge (supra), can be considered as an authority applicable to the exercise of the Minister’s discretion under section 6(2). ... And Lord Bramwell said, at page 678: “Then it is said that there was something he had considered which he ought not to have considered, and something he had not considered which he ought to have, and so he had not considered the whole circumstances and them only. ... These arguments were all carefully considered by the Court and rejected. ...
TCC
Dysert v. The Queen, 2013 DTC 1070 [at at 373], 2013 TCC 57
Therefore, the application of the tie-breaker rules in paragraph 2 of Article IV of the Treaty will need to be considered and applied. ... In that, he was not atypical of his contemporaries and the relevant factors must be considered in that context. ... Other aspects of the Gaudreau decision were considered by the Federal Court of Appeal and upheld at 2005 FCA 388 ...
TCC
Teelucksingh v. The Queen, 2011 DTC 1052 [at at 272], 2011 TCC 22
The value of his pedigree plus the black gene would be considered worth pursuing as a young stallion ... I checked my figures with colleagues in the business of professional horse care, and these figures can be considered fair. ... I checked my figures with colleagues in the business of professional horse-care and these figures can be considered fair ...
TCC
Westward Explorations Ltd. v. The Queen, 2006 DTC 2443, 2006 TCC 105
Asked if he considered the reserve calculations made by the Muscocho staff when the Mine closed in 1990, Mr. ... Lawrence only used "proven" so that what the Muscocho staff considered "possible" ore became "proven". ... Farquharson considered them to be two distinct categories. As far as Mr. ...
FCTD
Dand Auto Parts Ltd. v. The Queen, 90 DTC 6533, [1990] 2 CTC 385 (FCTD)
He had considered buying a horse ranch but was unable to do so. Therefore, he purchased a farm and spent, in his first year of operation $100,000 for bloodstock. ... Before the purchase of livestock, Dand consulted with Milburn, who, according to Dand, was considered one of the best horsemen regarding pedigree determination. ... I do not deny that this is a factor to be considered in the totality of all the facts. ...
TCC
Loukras v. MNR, 90 DTC 1557, [1990] 2 CTC 2044 (TCC)
He then considered the matter again when he reassessed the appellant on August 30, 1982 for the 1978 taxation year. He presumably considered the matter again when he vacated that reassessment on November 10, 1983. ... Urie, J, considered the judgment of Kearney, J. in the Exchequer Court in the case of M.N.R. v. ...
TCC
Staltari v. The Queen, 2015 DTC 1130 [at at 818], 2015 TCC 123
Counsel questioned why this idea would not have come from his father if indeed it was considered at the time of purchase. [51] Counsel also noted that Mr. ... No. 1805 (QL), 266 N.R. 36, 2000 DTC 6615, the Federal Court of Appeal considered the impact of the taxpayer’s motivation in making a gift and observed at paragraph 8: 8 ... ... The question of what is income in the context of section 3 is often considered together with the “source concept”. ...
FCTD
Fibre Co. Pulp Inc. v. The Queen, 94 DTC 6325, [1994] 2 CTC 114 (FCTD)
If the Crown adopts that advice as argument, it will be before the Court, without its being considered to be evidence. ... (passages by Linden J.A. considered.); Ocean Construction Supplies Ltd. v. Minister of Finance (1977), 1 W.W.R. 258 (B.C.S.C.).opNot surprisingly the defendant's arguments considered some of the same jurisprudence. ...
FCA
St. Michael Trust Corp. v. Canada, 2010 DTC 5189 [at at 7361], 2010 FCA 309, aff'd sub nom Fundy Settlement v. Canada, 2012 DTC 5063 [at 6881], 2012 SCC 14
Justice Woods considered it unnecessary to reach a conclusion on that point and she declined to do so. ... Michael Trust Corp., in its own right and in relation to its own tax affairs, would be considered a resident of Barbados and not a resident of Canada. ... It remains to be considered whether the present case falls within that rule. ...