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.), c. 1) 9. (1) Subject to this Part, a taxpayer's income for a taxation year from a business or property is his profit therefrom for the year. 18. (1) In computing the income of a taxpayer from a business or property no deduction shall be made in respect of (a) an outlay or expense except to the extent that it was made or incurred by the taxpayer for the purpose of gaining or producing income from the business or property; (9) Notwithstanding any other provision of this Act, (a) in computing a taxpayer's income for a taxation year from a business or property (other than income from a business computed in accordance with the method authorized by subsection 28(1)), no deduction shall be made in respect of an outlay or expense to the extent that it can reasonably be regarded as having been made or incurred (i) as consideration for services to be rendered after the end of the year, (ii) as, on account or in lieu of payment of, or in satisfaction of, interest, taxes..., rent or royalty in respect of a period after the end of the year, or (iii) as consideration for insurance in respect of a period after the end of the year...; (b) such portion of each outlay or expense made or incurred as would, but for paragraph (a), have been deductible in computing a taxpayer's income for a taxation year shall be deductible in computing his income for the subsequent year to which it can reasonably be considered to relate;... ... (a) The interpretive framework 29 It is appropriate to begin the consideration of profit with s. 9(1) of the Act, which defines a taxpayer's income for a taxation year from a business or property source as “his profit therefrom for the year.” ... The importance of the “match” flows from the critical role timing considerations play in taxation matters. 49 While at first glance this statement might be taken to support the recognition of the matching principle as a rule of law, such was not the true meaning of these remarks. ...

One aspect of the consideration paid for the transferred shares was the issuance and delivery of a note for an amount equal to that of their ACB.  ... The procedural issues raised in these cases are of only minor importance. [26]                           However, the way the evidence was adduced in these cases certainly had a significant impact on the consideration of the issues, as it facilitated proof of the taxpayers’ allegations.  ...

Aylesworth J.A. said: There remains for consideration the effect of the evidence and findings made by the trial Judge with respect to the Kroy-Fulton deal so far as they affect Ciglen and the position in law of the respondent Black in the appeal as a whole. ... Aylesworth J.A. concluded his consideration of the guilt of the accused in reference to the Kroy-Fulton deal in these words: When the serious errors in law to which reference has been made are corrected, the facts as found by the trial Judge in the Kroy-Fulton deal lead inevitably to one conclusion—the guilt of the accused Ciglen as charged. ... So, in the present case, it is submitted that the learned trial judge had expressed a reasonable doubt not only on the three propositions of law, with which I have dealt, but for other reasons and that reasonable doubt was not within the consideration of the Court of Appeal, it not being a question of law alone. ...

This requires a separate consideration of the conclusions reached with respect to s. 60 and s. 63 of The School Act. ... The subsection can only affect the notice until challenged on appeal, and it appears to have no bearing on the question of onus on such appeal, which is determined by the considerations already stated. ... Commission des Relations de Travail du Québec, [1967] S.C.R. 697, have properly emphasized what other cases have reflected in their consideration of the force of s. 96 (as for example, Dupont v. ...

  [3]                               The parties in this case agree that while there may be a number of factors making a production order unreasonable, this appeal is limited to a consideration of the reasonableness of the financial burden of compliance.  ...   [11]                           Secondly, Vaillancourt J. emphasized that production orders are obtained in ex parte proceedings, proceedings which are not therefore conducive to consideration of the issue of compensation.  ... The nature of [the] third party’s business is also an underlying consideration. ...

It is agreed that sec. 24 is the applicable provision, but it can be seen at once that the first consideration raised is that of the meaning of certain words and expressions used both in that and the other provisions. ... Before turning to a consideration of authorities it is essential first to consider the particular legislation which is here in question. ... The language used in the English judgments must of course be understood with reference to the cases then under consideration.” ...

With respect, my consideration of the real substance and intent of the legislation under review leads me to a different conclusion. ... The tax under consideration is essentially an export tax imposed upon oil production. ... That consideration is of minor importance today. In assessing the policy of a new form of taxation the jurisprudence offers no certain guide. ...

Apart from these considerations, it would appear that those parts of the definition of “wages” which relate to moneys payable out of revenues of the Dominion are severable from the other parts of the definition. ... Without discussing, for the moment, whether or not the statute under consideration imposes a direct or indirect tax, it might be advisable to ascertain what is the meaning of the word “taxation” used in sections 91 and 92 of the British North America Act. ... The exemption from taxation by provincial legislation of the salaries of judges would be based partly on different considerations than those that would apply to civil servants. ...

In coming to their conclusion, the adjudicators considered the complainants’ evidence and submissions, the governing jurisprudence, the purpose, nature and scheme of the CHRA  , and relevant policy considerations. ... What is controversial is consideration of complaints that, in substance, solely target legislation. ... However, it is not for a reviewing court to reweigh policy considerations. ...

In the cases under consideration, the company responsible for collection and remission of income tax and GST borrowed money from a lending institution.  ... It is in effect a sale by a company of its accounts receivable at a discounted value to the factoring company for immediate consideration.  ... It is clear that in enacting the sections of the ITA and ETA under consideration Parliament was attempting to ensure the priority of the claim of the MNR over that of other creditors.  ...