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(“AVL”) issued to him by AVL for $1.00 consideration. The respondent’s position is that the value of these shares was income to the appellant from an office or employment under subsection 5(1) or paragraph 6(1)(a) of the Income Tax Act on the basis that they represented remuneration for past services to AVL ...   [16]     Moreover, we have subsections 27(3) and (4) of the Alberta Business Corporation Act which reads:            A share shall not be issued until the consideration for the share is fully paid in money or in property or past service that is not less in value than the fair equivalent of the money that the corporation would have received if the share had been issued for money.            In determining whether property or past service is the fair equivalent of a money consideration, the directors may take into account reasonable charges and expenses of organization and reorganization and payments for property and past services reasonably expected to benefit the corporation ...

. $367,000, in lieu of all periodic payments provided for in the 1972 agreement; NOW, THEREFORE, in consideration of the premises and of the covenants hereinafter made, the parties hereto agree with each other as follows: 1. ... In consideration of the aforesaid payment, Mr. Young and Mrs. Young, do hereby each agree to act as a consultant to KFC and to perform such dignified duties in the promotion of the business of KFC as shall be mutually agreed upon by Mr. ... Young which continued and endured in a manner that surmounted written agreements and contracts and constituted a business relationship of service and consideration for one another and their respective families and corporations which terminated upon Pepsico taking over KFC and the signing of Exhibit A-4. ...

It is to be noted that the learned Chief Justice used the firmly established principle that the taxing statute must be interpreted by the consideration of the words thereof in the ordinary, proper, and natural sense, and that doing so he found himself able to distinguish between the two words ‘‘produced’’ and “manufactured”. ... Vandeweghe Limited, supra, Duff, C.J., upon commenting that the words ‘‘produce’’ and “manufacture” were not words of any very precise meaning, sought an aid to construction in consideration of the exemptions from the impositions which were listed in subsection (4) of Section 86 of the then statute. ... I view these considerations of both the exemptions in Schedule III to the Excise Tax Act and the items in the Customs Act as being confirmatory of my view that the legislators intended that the words ‘‘manufactured’’ or ‘‘ produced’’ should encompass goods such as the polished marble slabs in question in this appeal. ...

Although there is no limitation on the timing of a Rule 82 application, one of the considerations to be taken into account is the stage of the proceedings, particularly when none of the preliminary steps have been initiated. ... However, she considered the stage of the proceedings to be a relevant consideration in that case. ... The Queen, 2012 TCC 135, [2012] 5 C.T.C. 2005, at paragraph 25, that the interests of justice is also an important consideration. [29]            In my view, the Tax Court Judge did not commit any error in weighing the interests of justice against the timing of the application. ...

While the CRA did not require tax to be withheld from the benefit amounts described in Section 4 herein, the consideration of these amounts in the Application wrongly disqualifies the individual Appellants from a waiver of withholding tax to which they were duly entitled based on Canadian tax law, and further created undue burden on both the individual Appellants, who would have to file T1 returns to recover tax amounts withheld in violation of the Act, and on Hackett Songs LTD, which would have to withhold, remit, and account for such withheld tax amounts. 6.    ... Deputy Federal Commission of Taxation (S.A.); ex parte Hooper (1926), 37 C.L.R. 368 at 373: An ‘assessment’ is not a piece of paper; it is an official act or operation; it is the Commissioner’s ascertainment, on consideration of all relevant circumstances, including sometimes his own opinion, of the amount of tax chargeable to a given taxpayer. ... The following extract is particularly relevant: 7  Consideration of the purpose of subsection 153(1) leads to the same conclusion. ...

That provision states in relevant part: Allocation of amounts in consideration for property, services or restrictive covenants Contrepartie mixte 68 If an amount received or receivable from a person can reasonably be regarded as being in part the consideration for the disposition of a particular property of a taxpayer, for the provision of particular services by a taxpayer or for a restrictive covenant as defined by subsection 56.4(1) granted by a taxpayer, 68 Dans le cas où il est raisonnable de considérer que le montant reçu ou à recevoir d’une personne représente en partie la contrepartie de la disposition d’un bien d’un contribuable, la contrepartie de la prestation de services par un contribuable ou la contrepartie d’une clause restrictive, au sens du paragraphe 56.4(1), accordée par un contribuable, les règles ci-après s’appliquent: (a) the part of the amount that can reasonably be regarded as being the consideration for the disposition shall be deemed to be proceeds of disposition of the particular property irrespective of the form or legal effect of the contract or agreement, and the person to whom the property was disposed of shall be deemed to have acquired it for an amount equal to that part; a) la partie du montant qu’il est raisonnable de considérer comme la contrepartie de cette disposition est réputée être le produit de disposition du bien, quels que soient la forme et les effets juridiques du contrat ou de la convention, et la personne qui a acquis le bien à la suite de cette disposition est réputée l’acquérir pour un montant égal à cette partie; … […] [30]            Coast Capital submits that the Tax Court Judge’s allowance of the addition of section 68 of the ITA to the provisions to be relied upon is inconsistent with her refusal to allow the pleading invoking the cost argument, set out in paragraphs 23(f), 30A and 37A of its proposed Amended Notice of Appeal. [31]            While I agree that it might not have been necessary to allow Coast Capital to add section 68 of the ITA to the list of statutory provisions that it relied on, it does not follow that the Tax Court Judge erred in failing to allow the amendments to raise the cost argument. ...

The role of the Court on judicial review is generally limited to a consideration of the record that was before the decision-maker. ... XXVI (3)). [48]            A further consideration is the broad margin of appreciation afforded to the Minister in the context of the MAP process. The Court owes deference to the “range of considerations” underlying the government-to-government negotiations: see Khadr, at para 46. [49]            In these particular circumstances on a reasonableness standard of review, the margin of appreciation owed to the Minister is very broad: (Canada (Attorney General) v Boogaard, 2015 FCA 150 at para 64). [50]            Accordingly, I conclude that reasonableness is the appropriate standard of review.  ...

In consideration of the sureties to be subscribed by you for the company’s benefit, the company undertakes to pay you annual fees corresponding to 0.25% of the value of the debts guaranteed by you, such fees to be payable as soon as the company has sufficient cash assets. ... In consideration of these advances the company undertakes to pay you interest at the annual rate of 12% on advances made by you, such interest to be payable as soon as the company has sufficient cash assets. ... Respondent’s counsel submitted, and I agree, that it is not sufficient to make a general allegation that the appellant anticipated some participation in the profits of Threads at some unstated time in the future and on that basis to argue that some consideration for the guarantee existed. ...

In making assessment No. 08 720 of May 2, 1995 pursuant to s. 160 of the Income Tax Act, the Minister of National Revenue assumed inter alia the following facts: (a)            on or about November 12, 1993, by notarial deed, Les Placements Gaber Inc. transferred [denied] to the appellant a property located at 3145 Route du Lac Ouest in Alma; [admitted as to the remainder] (b)            the said notarial deed stipulated that the consideration given by the appellant to the transferor ["transfer" denied], Les Placements Gaber Inc., was $22,000; [admitted as to the remainder] (c)            the fair market value of the said property on November 12, 1993 was not less than $71,500; [denied] (d)            the transfer [denied] on November 12, 1993 of the property located at 3145 Route du Lac Ouest in Alma conferred on the appellant a benefit of at least $20,685.06; [denied] (e)            the appellant is the spouse of Ghislain Bergeron, who is the brother of Gaétan Bergeron, the sole shareholder in Les Placements Gaber Inc., the transferor [denied]; [relationship admitted] (f)             on May 2, 1995, the date of assessment No. 08 720 issued to the appellant pursuant to s. 160 of the Income Tax Act, Les Placements Gaber Inc. had a tax liability of $20,685.06 for the taxation years 1986 to 1988 and 1990, as confirmed by Notices of Assessment in 1991 and 1993; [admitted] (g)            on May 2, 1995, the date of assessment No. 08 720 issued to the appellant pursuant to s. 160 of the Income Tax Act, Les Placements Gaber Inc. had a tax liability of $3,341.65 from non-remitted source deductions.... ... This sale is also made in consideration of the repayment of money owed to the vendor, which the said vendor acknowledges having received prior to this agreement, and general and final release is given therefor. [22]          A resolution of Les Placements Gaber Inc. on October 22, 1993 to sell the immovable to Colombe Martel stipulated [TRANSLATION] "that the selling price shall be the assumption of the mortgage granted to the Caisse de Dépôt et Placement du Québec pursuant to a deed registered on June 23, 1978 under No. 130-916, and the repayment of the amounts owed to the vendor" (Exhibit I-1, tab 15). [23]          Ghislain Bergeron testified that the reason the appellant alone acquired the house was that he felt he was not entitled to it because he had declared bankruptcy in 1992. [24]          On April 26, 1994, as a result of the economic situation, Les Placements Gaber Inc. declared bankruptcy as did Gaétan Bergeron. ...                 (1)            Where a person has, on or after the 1st day of May, 1951, transferred property, either directly or indirectly, by means of a trust or by any other means whatever, to                 (a)            his spouse or a person who has since become his spouse,                 (b)            a person who was under 18 years of age, or                 (c)            a person with whom he was not dealing at arm's length, the following rules apply:                 (d)            the transferee and transferor are jointly and severally liable to pay a part of the transferor's tax under this Part for each taxation year equal to the amount by which the tax for the year is greater than it would have been if it were not for the operation of sections 74 to 75.1, in respect of any income from, or gain from the disposition of, the property so transferred or property substituted therefor, and                 (e)            the transferee and transferor are jointly and severally liable to pay under this Act an amount equal to the lesser of                                 (i)             the amount, if any, by which the fair market value of the property at the time it was transferred exceeds the fair market value at that time of the consideration given for the property, and                                 (ii)            the aggregate of all amounts each of which is an amount that the transferor is liable to pay under this Act in or in respect of the taxation year in which the property was transferred or any preceding taxation year, but nothing in this subsection shall be deemed to limit the liability of the transferor under any other provision of this Act. (2)            Minister may assess transferee.                 ...

Coseka entered into a written option agreement with an arm’s length company, 341063 Alberta Ltd. (“341063”) whereby in consideration of $15,000 it gave 341063 an option exercisable prior to December 30, 1986 to purchase all of the issued and outstanding 2,050 common, 240 preferred, 150 preferred series B and 1,396 preferred series C shares of Coseka U.S. for a purchase price of $0.01 per share. 4. 341063 was owned by Phelps Drilling International Limited (“Phelps”), which was owned to the extent of 24% by Bramalea Limited. ... The bank released them on December 9, 1986 in consideration of Coseka’s agreement to pay it one-half of the net amount received by Coseka for the shares of 346045 as well as one half of the amount received under a similar transaction with Westbridge Capital Corporation relating to the rest of the shares of Coseka U.S. 9. ... However if A Corp. were to sell the shares of X Corp. to C Corp. at a loss (and not take back shares, but instead some other form of consideration) A Corp.’s loss would be denied under paragraph 85(4)(a), and the effect of the denial of its loss would not be alleviated under paragraph 85(4)(b) because it owned no shares in C Corp. ...