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S.C. 1970-71-72, c. 63) (the "Act") was amended and was amended badly, hastily, and without proper consideration of what it was doing. I think that by enacting paragraph 3(f) as it was enacted, without giving proper consideration to what was intended by section 63, was a quick patch-over and enacted in order to negate the effects of McLaren and Fiset, supra. ...

The result is that the Court finds that farm buildings and improvements, which were not described in assumption 3(3) are capital assets for which the appellant paid a consideration in his 1988 purchase. ... In addition, a back-up generator that Alberta Agricultural Development Corporation valued at $5,000, is not in consideration because it is not yet in operation. ...

That leaves for determination, the position of the respondent in relying on subparagraph 40(2)(g)(ii) of the Act which reads as follows: a loss from the disposition of a debt or other right to receive an amount, unless the debt or right, as the case may be, was acquired by the taxpayer for the purpose of gaining or producing income from a business or property (other than exempt income) or as consideration for the disposition of capital property to a person with whom the taxpayer was dealing at arm's length. ... M.N.R., [1990] 2 C.T.C. 2185; 90 D.T.C. 1655 (French) and 90 D.T.C. 1662 (English)) and her comments therein deserve serious consideration, as they respect the possible application of the Civil Code of Lower Canada. ...

Applicant's Position Counsel for the applicant admitted that the required time period for consideration by this Court had ostensibly expired but he put before the Court for consideration the case of City of Kamloops v. ...

Accordingly, a deal was struck whereby the appellant agreed to pay to the mortgagee, or proposed mortgagee, an amount in consideration of which the payee would reduce the interest rate on the contemplated mortgage to 17 per cent for a period of two years. ... The consideration paid by the appellant to the mortgagee is the amount in question in this appeal. ...

In the affidavit of value and true consideration to the transfer of NE 1, the Appellant swore that the value of the land and buildings was $3,000. 3. ... His explanation of his affidavit of value and consideration is not accepted. ...

SECTION 69: Insufficient considerations               (1) Except as expressly otherwise provided in this Act,  ...   ... On or about December 18, 1996, 118280 Canada transferred all its common shares in IRSL to 3325016 Canada in consideration of 50 Class C preferred shares of the latter corporation. ... On or about August 2, 1999, 3325016 Canada transferred 100 Class B shares of IRSL to 2165‑1153 Québec in consideration of 100 Class D shares of the latter corporation. ...

In reality, the issue may be summarized essentially as a question of establishing the fair market value of the 37,500 class G shares issued by Groupe SL in consideration of the transfer by Mr. ... Accordingly, counsel said, section 160 of the Act cannot apply since the fair market value of the consideration in shares was equal to the fair market value of the property transferred to Groupe SL. ... Counsel for the respondent then insisted on the necessity under section 160 of the Act to establish the fair market value of the consideration, that is, of the shares. ...

This consideration is not sufficient to support a legally‑binding contract. ... As there, the Appellant reflected the true consideration in the stated capital account. ...   [92]          That leaves for consideration the expenditures issue. ...

(“Kelso”) for a consideration greater than their fair market value. [2]              In the Minister’s view, subsection 146(9) of the Act is unambiguous. ... The first is whether the consideration paid by the Appellant’s RRSP for the Kelso Securities was greater than fair market value.  ... Those shares had no value when they were acquired and the consideration given for them exceeded their fair market value by $53,300. ...