Search - considered
Results 13041 - 13050 of 49499 for considered
TCC
Westcoast Energy Inc. v. The Queen, 2020 TCC 116 (Informal Procedure), aff'd 2022 FCA 57
… I have considered two examples of the use of the phrase [“in the course of”] in other legal rules. 49. ... Indeed, the multiplicity of the factors considered by the courts, and the importance of the facts of the particular case in determining the result, give a significant factual component to the question of whether an employee was acting “in the course of” employment when the wrong was committed: see Lewis N. ... Therefore, paragraph (a) must be considered, and eliminated, before paragraph (b) can be applied. ...
TCC
U.S.M. Canada Ltd. v. R., [1996] 2 CTC 2289, 97 DTC 192
Our examination was made in accordance with generally accepted auditing standards, and acccordingly included such tests and other procedures as we considered necessary in the circumstances. ... The Minister of National Revenue has considered the reasons set out in your objections and all the relevant facts. ... Gapp & Co. where evidence of a resale price two years after a notional valuation date was considered to be prima facie evidence that the notional valuation was too high. ...
SCC
Sherman Estate v. Donovan, 2021 SCC 25, [2021] 2 SCR 75
Dignity in this sense involves the right to present core aspects of oneself to others in a considered and controlled manner; it is an expression of an individual’s unique personality or personhood. ... That this requirement is considered a high bar serves to maintain the strong presumption of open courts. ... Dignity, used in this context, is a social concept that involves presenting core aspects of oneself to others in a considered and controlled manner (see generally Matheson, at pp. 327‑28; Austin, at pp. 66‑68). ...
FCTD
Democracy Watch v. Canada (Attorney General), 2023 FC 31
Conacher’s own opinion and are also inadmissible. [52] In arriving at this conclusion, I have considered the Applicants’ argument that, in its analysis in the seminal case of Valente, the Supreme Court cited opinion evidence of the sort upon which the Applicants seek to rely. ... Rather, they are factors that must be considered and balanced in the exercise of the Court’s discretion under Rule 312 (see Smart Cloud Inc v International Business Machines Corporation, 2021 FC 236 at para 39). ... As with institutional independence, the test for institutional impartiality is that described in Valente (see Lippé at p 143). [106] After identifying the applicable test, Valente analysed what should be considered as the essential conditions of judicial independence. ...
SCC
International Harvester Company of Canada, Limited v. The Provincial Tax Commission, the Commissioner of Income Tax, the Provincial Treasurer, and the Attorney-General for Saskatchewan, [1940-41] CTC 294
The charging section is section 9, of which subsections 3 and 4 must first be considered in this case. ... In a very fully considered judgment the Board confirmed the assessments made by the Commissioner of Income Tax. ... This claim was made before the Board and, although it does not seem to have received as much consideration there as it did before us, it was considered by them. ...
TCC
McKeown v. The Queen, docket 96-2732-IT-G
Nor had he considered the fact that he would have to repay the loan from Loron Inc. ... Racette explained that, all in all, there are no factors which, considered alone, would alter her opinion. ... Racette used the discounted cash flow method, which she considered the most appropriate in the circumstances. ...
TCC
Husky Energy Inc. v. The King, 2023 TCC 167, aff'd sub nomine Hutchison Whampoa Luxembourg Holdings S.À R.L. 2025 FCA 176
Glynn testified that nine of the 14 directors were considered “independent”. ... Li Ka-shing was not considered an insider in respect of those shares. [127] [124] Mr. ... A person that possesses an asset as his own is considered as the possessor of the property. 5. ...
Technical Interpretation - External
26 June 2003 External T.I. 2003-0007255 - ABIL-SPECIFIED INVESTMENT BUSINESS
If all of the corporation's activities fall within the definition of "specified investment business", it cannot be considered to carry on an active business, and as a result cannot be considered a small business corporation for the purposes of paragraph 39(1)(c) of the Act. A loss on the disposition (or deemed disposition) of a debt owing by such a corporation cannot be considered a business investment loss. ... It cannot therefore be considered a small business corporation at the present time, and any loss from the disposition (or deemed disposition) of the shareholder loans at the present time would not be considered a business investment loss. ...
Technical Interpretation - External
28 June 2010 External T.I. 2009-0342671E5 - Paragraph 149(1)(t) - non-resident insurers
Position: (1) Yes; (2) The gross premium income from the activities of the non-resident insurer as a whole should be considered. ... You have asked us to clarify whether only the activities of the Canadian branch should be considered in applying the threshold tests in paragraph 149(1)(t) and subsection 149(4.2) of the Act and the formula in subsection 149.1(4.1) of the Act. ... In order for a Canadian resident insurer to qualify for the exemption from Part I tax pursuant to paragraph 149(1)(t) of the Act, the combined gross premium income from all forms of insurance sold by the Canadian resident insurer and by certain other insurers would be considered. ...
Technical Interpretation - External
30 October 2014 External T.I. 2013-0500491E5 - Pension from XXXXXXXXXX
The European Union is an international organization as defined in section 2 of the Foreign Missions and International Organization Act, and in our view would not be considered a government of a country other than Canada. Therefore, the tax withheld by the European Union on the pension income is not considered an income tax paid to a government of a country, and the foreign tax credit provided by subsection 126(1) is not available. ... The European Union is an international organization as defined in section 2 of the Foreign Missions and International Organization Act, and, in our view, would not be considered a government of a country other than Canada. ...