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A further question arises, Was the expenditure under consideration ‘‘exclusively’’ incurred in earning income? ... In coming to a conclusion upon that question in this case, I find the many decisions referred to by counsel of little assistance, as the enactments under consideration in them are expressed in terms varying, if not entirely different, from the Income War Tax Act. ... In any consideration of this question, a certain degree of latitude must, I think, be allowed. ...

The point in issue now before us did not arise for consideration in that case. ... What has already been said disposes of the suggestion that the income is income of anyone other than the unascertainable aged and deserving poor of Colne and I do not find any assistance in the English cases referred to, which deal with statutes expressed in terms totally unlike the enactment under consideration. ... Section 65 provides for the Court permitting any fact or statutory provision not set out in the notice of appeal or notice of dissatisfaction to be pleaded or referred to and empowers the Court to refer the matter back to the Minister for further consideration. ...

Receipt is hereby acknowledged by me, on account of the purchase price above mentioned, of the sum of Fifty-seven Thousand Five Hundred Dollars ($57,500), the balance of the said purchase price amounting to One Million Ninety-two Thousand Five Hundred Dollars ($1,092,500) to be paid by you on or before 12 o’clock noon, on Thursday, November 3, 1932, and in consideration of the foregoing I hereby undertake to forthwith deliver to you or your nominees, good and marketable deeds of title as well as contracts, undertakings and other documents and papers appertaining to the assets of the A.O.A., and to give to you or your nominees access to any and all books of statements concerning the Company, and to permit you or your nominee to visit the premises and properties owned by the Company and to facilitate in every way a thorough inspection by you of the affairs of the Company. ... Pritchard, who owned a certain number of shares of Automobile Owners’ ‘Association, Limited, wrote to Trudeau as follows (exhibit 6): I hereby agree to deliver or cause to be delivered and transferred to you or your assigns or nominees all of the common and/or preferred shares appearing in my name in the Subscription Book of the Automobile Owners’ Association (1929) for and in consideration of the sum of $50,000, should you consummate your sale as outlined in letter of even date to Harry Snyder. ... Counsel for respondent objected to this evidence as tending to contradict the allegation contained in paragraph 12 of the statement of claim; judgment on the objection was reserved; after giving the matter due consideration, I have reached the conclusion that the objection is unfounded. ...

In consideration of the sum of One hundred and sixteen thousand six hundred and forty dollars ($116,640.00) heretofore paid to the Dominion Company and for the sum of One dollar ($1.00) each in hand paid to the Dominion Company and the Securities Company upon the execution of this agreement, the receipt whereof is hereby acknowledged, the Dominion Company and the Securities Company hereby release the other parties hereto from all claims and demands, present and future, in respect of the following covenants in the Indenture hereunto annexed as Schedule "‘A’’ hereto which are to the following effect:— FIRSTLY, that the lessee in the said Indenture of the 12th of June, 1879, should, during the demised term, keep the said telegraph lines, system and plant in good working order and should pay all costs of renewals thereof and expenses of carrying on the same, and SHCONDLY, that on the last day of the said term, or on the sooner determination of the estate thereby granted, the lessee should peaceably and quietly leave, surrender and yield up unto the Dominion Company all and singular the said demised premises and property in good working order and repair with an adequate supply of instruments and plant of the most improved character then in use on telegraph lines in America. 2. ... As the consideration for the assets (subject to liabilities) hereby agreed to be sold by the Vendor to the Purchaser, the Purchaser shall deliver the entire issue of such bonds and the entire number of certificates of interest hereinbefore referred to pro rata to the individual shareholders of the Vendor, as its nominees, upon surrender to the Purchaser of stock certificates with power of attorney thereon duly endorsed representing the shares held by the shareholders in the Vendor. ... Under the agreement (Exhibit 2) the sum of $116,640.00 is the consideration for a release of the covenants and a transfer of the telegraph system in 1978. ...

Allison, and having made further enquiries and having given full consideration to the matter and being of the opinion that the said Frank H. ... Noxzema Chemical Company of Canada, Limited, [1942] S.C.R. 178, [1942] C.T.C. 21, the question for consideration was the right of the Minister, under s. 98 of the Special War Revenue Act, Cap. 179, R.S.C. 1927, to fix fair prices upon which sales and excise taxes should be paid. ... I should have thought that the concluding words of ss. 9, as added by the amendment, would have had greater clarity if they had read thus: CC shall be received as evidence of the document and of the contents thereof and of the Minister’s signature thereto^ 9 Upon further consideration of the matter, I have reached the conclusion that the ‘ ‘ document, ‘ ‘ which is made evidence, includes the signature of the Minister or in other words everything contained therein, within the delegated power of the Minister. ...

Inland Revenue (1938), 21 T.C. 608 at 619:. no infallible criterion emerges from a consideration of the case law. ... In the negotiations for the settlement of the compensation which Doulton would pay to the taxpayer the president of the taxpayer wrote a letter to Doulton one paragraph of which was as follows: At this point in our calculation, we stopped and gave thoughtful consideration to the matter of how much of the successful development of the Doulton market in Canada has been a joint effort, in the sense that you as manufacturers had created an acceptable product, and that we have done a fine job of establishing and servicing a distribution organization which you can be proud to take over without modification. Thurlow, J. at p. 187 (p. 244) said: On the whole therefore having regard to the importance of the Doulton agency in the appellant’s business, the length of time the relationship had subsisted, the extent to which the appellant’s business was affected by its loss both in decreased sales and by reason. of its inability to replace it with anything equivalent, to the fact that two of the appellant’s employees became employees of the Doulton subsidiary on the termination of the relationship and the fact that from that time the appellant was in fact out of that part of its business, both as an agent and as a wholesale dealer, and particularly to the nature of the claim asserted in respect of which the payment was made, I am of the opinion that, except in so far as it was a consideration for services rendered to Doulton & Co. ...

Such planning is not objectionable in itself, as long as a true consideration has been given by the company receiving the management fees, the amount of the fees corresponds to the fair market value of the services obtained considering that the two companies in question are related, and the documentation is adequate ...   [15]          The evidence adduced does not make it possible to find, with a sufficient degree of certainty, that the appellant did receive a true consideration for the $80,000 paid annually as management fees. ...

The decision of the Tax Court in Cassidy's came shortly after I took this matter under reserve, and following further arguments of counsel, I gave the matter further consideration. ... I turn, therefore, to a consideration of the conditions necessary to establish a right to claim a deduction pursuant to paragraph 18(1)(a). ...

The Vendor hereby sells, transfers and assigns unto the Purchaser and the Purchaser hereby accepts the sale, transfer and assignment of all the vendor’s exclusive right and concession under the Indentures for and in consideration of the price of one million, nine hundred and thirteen thousand and sixty dollars ($1,913,060.00) payable upon the execution hereof. ... On the other hand, he based his decision solely on a consideration of the proper interpretation to be given to the words franchise, concession or licence’’ in business practice on this continent. ...

“shared-custody parent” in respect of a qualified dependent at a particular time means, where the presumption referred to in paragraph (f) of the definition “eligible individual” does not apply in respect of the qualified dependant, an individual who is one of the two parents of the qualified dependant who   (a) are not at that time cohabitating spouses or common-law partners of each other,   (b) reside with the qualified dependant on an equal or near equal basis, and   (c) primarily fulfil the responsibility for the care and upbringing of the qualified dependant when residing with the qualified dependant, as determined in consideration of prescribed factors.   ...   [17]         The caregiving element is in clause (c), which reads:   (c) primarily fulfil the responsibility for the care and upbringing of the qualified dependant when residing with the qualified dependant, as determined in consideration of prescribed factors ...