Search - considered

The Minister of National Revenue has considered the reasons set out in your objection and all the relevant facts. ... This argument is considered because the issue potentially engages the Applicant’s right to launch its appeal to the Tax Court of Canada ... Any revised or amended notice that does not change the Minister’s decision cannot be considered a substitute for the Notice of Confirmation ...

When they first decided to amalgamate their potato growing operations he had considered the partnership form of carrying on the business but had rejected this because of complications in the signature on documents which would have to be signed by all three of them in many cases. ... This circumstance is, Of Course, one only of several to be considered, but it is usually of vital importance. ... This would not prevent income from the partnership being considered as farming income, however. ...

The sole issue between the parties regarding each of the four assessments is the date at which, for income tax purposes, an apartment complex is to be considered as having been effectively either sold or disposed of by the plaintiff. ... These clauses, in my view, constitute evidence that the parties considered that clause 11 transferred not only the right to collect rents, which were in fact collected throughout by the purchaser, but the actual property of the leases themselves, and not, as was argued by counsel for the plaintiff, evidence that the leases were never considered to have been transferred. ... It now remains to be considered whether, in the light of these findings, a sale has taken place according to the laws of the Province of Quebec. ...

He also considered the manner in which the benefit was to be used, the second of the matters suggested by Dixon, J, and the third, that is to say, the method of payment. ... After having considered these matters at length, it appears to me that the prédominent criteria point to the conclusion that from a practical and business point of view, the expenditure is more appropriately classified as a revenue expense and not as an outlay of capital. ... On the other hand, it is not the expected life of the street improvements that should be considered. ...

Further, I have considered that, in the course of this motion, twice proceedings came to a halt and adjournments were granted because of late production. I have considered carefully R. v. Pawlowski, (unreported), Ont. Gen. Div., Chadwick, J., March 29, 1992, on the power of the court to grant costs. ... The defence allegations raise the thought of the possibility of one accused shifting blame to another if separate trials were ordered, which was considered as strong grounds for not ordering separate trials in R. v. ...

On the other hand, the respondent considered the appellant present in Canada for a day if he spent any part of that day in Canada ... Deputy Attorney General of Canada                                                           Ottawa, Ontario [1]               In his notice of appeal the appellant raised other issues that were not considered in evidence nor in argument at trial and are therefore not considered in these reasons. [2]               Much of the appellant's evidence was to establish that he was resident in the Bahamas. ... It was difficult to determine if he was in Canada on certain days because of the colouring on the calendar or the legibility of the writing; in such cases I considered Mr. ...

It is considered to be "one of the nicest farm in the valley." Most of the work was completed by 1991. [10] The breeding barn included good ventilation, stall frames and was considered to be safe to prevent the horses from escaping and injuring themselves. ... He considered himself to be in the general practice of dentistry and does a lot of denture work. ... He worked six to seven hours a day and considered that to be a normal dentist's practice hours. ...

No authority is cited for the statement that costs can only be considered from the time litigation is initiated. [30]          In Murano et al v. ... It went on to say that factors considered by Revenue Canada included efforts shown to reduce costs and turn a profit and devotion of time to the operation. ... " He also said: "Costs can only be considered from the time litigation is initiated. ...

A creditor acting reasonably and honestly, must be given some latitude in determining the year in which a debt should first be considered to be a bad debt. ... The prudence of the creditor as a reasonable businessperson in making the determination might be considered as a means of objectifying a determination that might otherwise inappropriately accelerate a loss claim. ... The question of when a debt is to be considered uncollectible is a matter of the taxpayer's own judgment as a prudent businessman. ...

The classic rule is that evidence may be adduced of foreign law which is considered a fact but not of domestic law. ... Whether the CRA considered applying GAAR or considered applying any other section of the Act that is not referred to in the pleadings is not relevant. ... The questions and answers related to whether the CRA considered applying GAAR are not admissible ...