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Smiles [3], a bonus which the taxpayer was obliged to pay on the repayment of borrowed capital before the maturity of the debt was described by the Lord President as a lump payment as one of the considerations stipulated for a loan of capital; and was held to be entirely heterogenous to those outlays, the deduction of which is permitted to be necessarily incidental to the earning of profit, and the bonus was held not to be deductible. ... It is clear that, in the several sections of the Act under consideration, the word "gain" is used interchangeably for "profit". ... After much consideration of the able arguments presented to us by counsel on behalf of the companies, I cannot bring myself to the view that these expenditures [Page 105] come properly under our statute as allowable deductions. ...

(b) By agreement dated September 20, 1949, Innes agreed to withdraw his application for a permit in consideration for Peace River Natural Gas Co.’s undertaking that when the permit was issued, it would stand possessed in trust for Innes of an undivided one-tenth interest in the permit, in any leases issued pursuant to it, and in any petroleum or natural gas [Page 418] recovered therefrom, subject to the payment by Innes of one-tenth of the costs incurred by Peace River Natural Gas in exploring, developing and drilling on the land. ... On January 2, 1952, Yankee Princess Oils acquired from Atlantic Oil Company (which company later changed its name to Canadian Atlantic Oil Company) a farm out agreement wherein Yankee Princess Oils agreed to drill on lands owned by Atlantic Oil Company at no cost to that company in consideration for acquiring a 50 per cent interest in an oil lease held by Atlantic Oil Company. ... There is no suggestion that in any of the transactions under consideration he obtained for himself a personal profit at the expense of any of such companies, or that he had placed himself in a position where he should account for such profits as a trustee. ...

The legislation here did not affect all members of the public alike, and this fact was a central consideration to the court's exercising its discretion against giving respond­ent standing. ... An explanation of this exception is that it involved a public right to see that municipal ex­penditures were lawfully made, being expenditures which were limited by considerations that do not apply to a province or to Canada. ... This, in my view, is a central consideration in the exercise of the Court's discretion against giving standing here to the plaintiff respondent. ...

Section 4 defining income from a business or property as ‘‘the profit therefrom’’ would appear to negate the consideration of losses. ... However, aceording to Maxwell (On Interpretation of Statutes, 11th ed., p. 37): Where a part of an Act has been repealed, it may, although not of operative force, still be taken into consideration in construing the rest, for it is part of the history of the new Act. ... It was obviously drawn up with great care and special consideration was given to the fiscal consequences of the provisions for payments to a withdrawing partner or to the estate of a deceased partner. ...

But other considerations arise where the right of enjoyment is deferred by a trust for accumulation and where, as here, some of the beneficiaries are or may be unborn and the shares of those in esse are not presently ascertainable. ... After giving to the provisions of secs. 5, 11(1) and 13(1) much thought and consideration, my conclusion is that in respect to income directed to be accumulated by a trustee for future distribution amongst person wholly or partially unascertained, some of them within and some of them without Ontario, he is not assessable. ... The view I have taken of the assessment appeal proper—and which I understand finds favour with the majority of the members of the Court—suffices to dispose of the liability of the appellant for the taxes in question and renders unnecessary consideration of the constitutional question presented in the action tried before Orde, J. ...

We turn, first, to some of the considerations applicable to this case as reflected in the National Energy Program. ... The following considerations are recited in the Program document (the numbering and the underlining is ours): [1.] ... The same consideration would apply also to Bill C-57 which had emerged before the hearing in the Alberta Court of Appeal and was before the Court. ...

The claimed right implicates an international boundary and, consequently, geographical considerations are clearly relevant to the determination of whether the trading in this case is integral to the Mohawks’ culture. ... There are, however, additional considerations for allowing the appeal.  ... If this is an obvious proposition, it must nonetheless be stated.   40           With these principles in mind, I turn now to the consideration of whether the evidence offered in the present case in fact supports an aboriginal right to bring goods across the St. ...

The division of powers analysis allows no recourse to balancing or proportionality considerations. ... As a result, it readily passes the threshold test and warrants consideration as a possible matter of national concern. ... (As I will discuss below, this is a significant consideration militating against the Act   ’s constitutionality.) ...

Which the department supervisors take into consideration when setting their prices. ... The trading in of second-hand automobiles was cited as an example......., In my opinion, the same reasoning which led the Privy Council to conclude, in the Kingcome and Conlon cases, that the respective statutes there under consideration imposed direct taxation is properly applicable to the Act now under consideration and is not rendered inapplicable because the present statute applies to durable as well as to consumable goods. ... In the instant case consideration must be given to what was decided by this Court with respect to federal sales tax, in a case mentioned by Hughes, CJNB: The King v Henry K Wampole & Co Ltd, [1931] S.C.R. 494, where tax was claimed on samples produced for free distribution. ...

  [48] The joint venture participants collectively acquired a 30.35% undivided interest in the data from Compton for a total consideration of $6,373,335.  ... The Minister also concedes that the “restrictions on an agent’s authority are relevant considerations in the arm’s length analysis” (Minister’s factum on cross-appeal, at para. 36).  ... Both the cash and note were given to Compton Resource Corporation (“CRC”) as consideration for seismic data, which is geophysical information used to locate oil and gas reserves.  ...