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In such cases, consideration may be given to waiving penalties and interest in whole or in part for the period beginning on the first payment due date under the payment arrangement until the amounts owing are paid, provided the agreed payments are made on time. 9. ... In such a case, consideration may be given to waiving interest in all or in part for a period from when payments commence until the amounts owing are paid provided the agreed payments are made on time.                                                 10. ... [W]hen the Minister exercises his discretion under subsection 220(3.1), he is required to take into account considerations relevant and unique to that taxpayer alone. ...

In such cases, consideration may be given to waiving penalties and interest in whole or in part for the period beginning on the first payment due date under the payment arrangement until the amounts owing are paid, provided the agreed payments are made on time. 9. ... In such a case, consideration may be given to waiving interest in all or in part for a period from when payments commence until the amounts owing are paid provided the agreed payments are made on time.                                                 10. ... [W]hen the Minister exercises his discretion under subsection 220(3.1), he is required to take into account considerations relevant and unique to that taxpayer alone. ...

In such cases, consideration may be given to waiving penalties and interest in whole or in part for the period beginning on the first payment due date under the payment arrangement until the amounts owing are paid, provided the agreed payments are made on time. 9. ... In such a case, consideration may be given to waiving interest in all or in part for a period from when payments commence until the amounts owing are paid provided the agreed payments are made on time.                                                 10. ... [W]hen the Minister exercises his discretion under subsection 220(3.1), he is required to take into account considerations relevant and unique to that taxpayer alone. ...

In such cases, consideration may be given to waiving penalties and interest in whole or in part for the period beginning on the first payment due date under the payment arrangement until the amounts owing are paid, provided the agreed payments are made on time. 9. ... In such a case, consideration may be given to waiving interest in all or in part for a period from when payments commence until the amounts owing are paid provided the agreed payments are made on time.                                                 10. ... [W]hen the Minister exercises his discretion under subsection 220(3.1), he is required to take into account considerations relevant and unique to that taxpayer alone. ...

T-2 provides: 18.15(4) Notwithstanding the provisions of the Act out of which an appeal arises, the Court, in hearing an appeal referred to in section 18, is not bound by any legal or technical rules of evidence in conducting a hearing for the purposes of that Act, and all appeals referred to in section 18 shall be dealt with by the Court as informally and expeditiously as the circumstances and considerations of fairness permit. ... Rather, the provision was intended to provide Tax Court Judges with the necessary flexibility to enable them to deal as informally and expeditiously with an appeal as the circumstances of the case and considerations of fairness allow (see, for example, Ainsley v. ... Rather, the Tax Court Judge seemed to be concerned only about the relevance and reliability of the documents; the considerations most pertinent to his exercise of discretion in refusing to admit hearsay evidence under Khan, supra and Smith, supra. ...

It is immaterial, in my opinion, that the consideration received by the appellant for her shares happened to reach her directly from the Premier Company and not through the medium of the Security Company ... The basic rule under new subsection 84.1(1) is that the maximum amount that can be received by the transferor from the transferee corporation as proceeds in the form of any non-share consideration and the paid-up capital of the share consideration is restricted to the greater of the paid-up capital of the transferred shares and what could be called the actual non-arm's length adjusted cost base to the transferor of the shares.   New paragraph 84.1(1)(a) provides for a paid-up capital reduction for each class of shares of the purchaser corporation for which shares were issued as consideration for its acquisition of shares of another corporation. ...

The latter acquired the appellant’s shares for total consideration of $500,000. ... (“AuteurCo”) was incorporated and Public subscribed for 400 Class A shares for a total consideration of $400. c) On June 20, 2005, 9157‑4426 Québec Inc. (“Beneficiary1”) was incorporated and, on July 4, 2005, AuteurCo subscribed for 100 Class A shares of Beneficiary1 for a total consideration of $100.   ...

A supplier is defined in section 123 as "the person making the supply", and a recipient is defined as: (a)         where consideration for the supply is payable under an agreement for the supply, the person who is liable under the agreement to pay that consideration, (b)         where paragraph (a) does not apply and consideration is payable for the supply, the person who is liable to pay that consideration, and (c)         where no consideration is payable for the supply,             [...] ... Liability to pay for the supply will govern where there is consideration payable. ... Section 165 of the Act imposes GST on the value of the consideration for this supply and is the amount exempted under paragraph (h). ...

(b) a share (other than a share received by a taxpayer as consideration in respect of the disposition of personal-use property) of the capital stock of a corporation is owned by the taxpayer at the end of a taxation year and [...] ... In particular, it is my opinion that it was not reasonable to expect that PGL will be dissolved or wound up and will not begin to carry on business as of December 31, 1993 as required by clause 50(1)(b)(iii)(A). [11]       The letter went on to explain that the following 10 factors were taken into consideration in arriving at the above decision:             1.          ... The decision under review combines fact-finding with a consideration of the policy of tax administration, and requires a proper interpretation of the relevant provision of the Act. ...

Because of the personal pride in your products which the principals of our firm have always felt, the Doulton side of our business has had pre-eminent consideration in our sales efforts, and consequently the results rival in volume the total business of all our other agencies combined. ... Inland Revenue (1938), 21 Tax Cas. 608, Lord Normand (Lord President), said (ibid., at p. 619): ‘... no infallible criterion emerges from a consideration of the case law. ... On that sort of consideration this case might well have been different if the £4,000 had been paid because the taxpayer’s goodwill had been damaged. ...