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The points in issue seem to have been the subject of careful consideration by the taxing authorities, in respect of matters about which there may well be a variety of opinions. ...

Sections 86(1) and 89(1) of the Excise Tax Act read, in part, as follows: 86. (1) There shall be imposed, levied and collected a consumption or sales tax of eight per cent on the sale price of all goods (a) produced or manufactured in Canada (i) payable, in any case other than a case mentioned in subparagraph (ii) hereof, by the producer or manufacturer at the time when the goods are delivered to the purchaser or at the time when the property in the goods passes, whichever is the earlier, and (ii) payable, in a case where the contract for the sale of the goods (including a hire-purchase contract and any other contract under which property in the goods passes upon satisfaction of a condition) provides that the sale price or other consideration shall foe paid to the manufacturer or producer by instalments (whether the contract provides that the goods are to be delivered or property in the goods is to pass before or after payment of any or all instalments), by the producer or manufacturer pro tanto at the time each of the instalments becomes payable in accordance with the terms of the contract; * * * 89. (1) The tax imposed by section eighty-six of this Act shall not apply to the sale or importation of the articles mentioned in Schedule III of this Act. ...

However, “economically relevant characteristics of the situations being compared” may make it necessary to consider other transactions that impact the transfer price under consideration.  ... Nonetheless, while consideration of the Licence Agreement was not precluded, the question still remains as to whether he should have considered it. [44]                           Because s. 69(2) requires an inquiry into the price that would be reasonable in the circumstances had the non-resident supplier and the Canadian taxpayer been dealing at arm’s length, it necessarily involves consideration of all the circumstances of the Canadian taxpayer relevant to the price paid to the non-resident supplier.  ...

[This] dominates the consideration that the lots are purchased annually in anticipation of the lowering of the level of the ore deposit. And it dominates the consideration that the lots may only remain as portions of a virtual wasteland when the mine ceases to operate. ... One consideration may point so clearly that it dominates other and vaguer indications in the contrary direction. ...

It is not a case of the appellant acquiring Lot 166 subject to a mortgage or charge, but rather the acquisition by him of that lot and the business in consideration of which, inter alia, he gave his personal covenants under paragraphs (d) and (e), and, when he had done so, the will then provides ‘‘the said Lot 166 shall be and is hereby charged with the performance’’ of his personal covenants. ... Those payments were merely part of the consideration which the appellant agreed to pay as a term of acquiring all of the assets of the business theretofore carried on by his father. The fact that part of the agreed consideration was payable in instalments during his mother’s lifetime cannot affect the true nature of the transaction or render such payments any the less ‘‘payments on account of capital”. ...

Interest is, in general terms, the return or consideration or compensation for the use or retention by one person of a sum of money, belonging to, in a colloquial sense, or owed to, another. ... It was suggested, though not seriously urged as a material consideration, that there might be contracts providing for crop payments not related to money with “interest” accruing in the same form, to which the section would apply. ... I therefore leave out of consideration the 4 per cent rate specifically mentioned in the statute as it was made perfectly plain before us that as things stand no such rate is currently operative and has not been for some time. ...

., they are the first consideration in determining classification. For example, in Chapter 31, the Notes provide that certain headings relate only to particular goods. ... They reiterate that Rule 1 requires that the headings and Section or Chapter Notes are the first consideration in determining classification.  ... (c)   When goods cannot be classified by reference to [Rule] 3 (a) or 3 (b), they shall be classified under the heading which occurs last in numerical order among those which equally merit consideration. ...

That provision states that a “settlement made... in favour of a purchaser or encumbrancer in good faith and for valuable consideration” is not void against the trustee in bankruptcy, thus providing a bona fide exception to ss. 91(1) and (2). However, the provision is not available in the case of self-settlement because, (1) there is no “purchaser or encumbrancer”, and (2) there is no exchange of “valuable consideration”. ... In any event, I reject the view that ss. 67(l)(b) and 91 of the BIA are in conflict, and that the resolution of the case at bar requires me to choose one provision over the other on the basis of policy considerations. ...

The practical considerations to which I have referred earlier underlie this approach.                      ... As long as a reasonably effective procedure exists for the consideration of constitutional challenges, I fail to see why another procedure must be provided.  ... There are considerations of a historical and practical nature that militate in favour of this solution as well to which I shall advert later.  ...

First, it was not patently unreasonable for the Tribunal to give consideration to the terms of the GATT in interpreting s. 42   of SIMA  .  ... These criteria could reasonably be interpreted as encompassing, in a case such as this one, consideration of the strong potential for increased amounts of subsidized imports.  ... These criteria could reasonably be interpreted as encompassing, in a case such as this one, consideration of the strong potential for increased amounts of subsidized imports.                       ...