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TCC

Basell Canada Inc. v. The Queen, 2008 DTC 2108, 2007 TCC 685

In the respondent’s view, although a price tag was placed on the various assets acquired, the Asset Purchase Agreement clearly stated that the aggregate amount was the consideration for the transaction. ... The amount paid by the taxpayer to Anglo-Canadian under that agreement was considered by the majority of the court as being paid in consideration of the construction of the pipelines and not for the execution of the supply contracts per se. ... He did not pay this sum as the consideration for an assignment of the benefit of these contracts to himself; he took no assignment.”   ...
FCA

Bowater Canadian Ltd. v. The Queen, 87 DTC 5287, [1987] 2 CTC 47 (FCA)

The appellant also assigned to Bathurst all of the Series "B" Notes which it had acquired and ten per cent convertible notes in the sum of $1,866,400 each for nominal consideration. ... One consideration may point so clearly that it dominates other and vaguer indications in the contrary direction. ... They merely crystallise particular factors which may incline the scale in a particular case after a balance of all the considerations has been taken. ...
TCC

Wabush Iron Company Limited v. The Queen, 2009 DTC 814, 2009 TCC 239

  [6]               The Minister reassessed the Appellant on the basis that all of the amounts paid by the shareholders under the Pellet Sales Agreement were consideration for the pellets and were required to be included in its income. ...   [51]          Counsel also submitted that the consistent treatment of the amounts as revenue in the Appellant’s financial statements showed that the Appellant itself recognized that the payments were consideration for the pellets. ... Therefore, whether the TIP represented a reduction in rent or a payment in consideration of Ikea’s assumption of its various obligations under the lease, it clearly cannot be treated as a capital receipt and should have been included in Ikea’s income.  ...
TCC

Weronski v. MNR, 91 DTC 1105, [1991] 2 CTC 2431 (TCC)

U-1, was under consideration. It entitles adoptive parents to payments in respect of time taken off work by fathers to look after adopted children after their arrival home. ... There would then follow a consideration of the distinction under the provisions of s. 1 of the Charter. ... The second approach put forward by McLachlin J.A. in the Court of Appeal involved a consideration of the reasonableness and fairness of the impugned legislation under s. 15(1). ...
FCTD

Cal Investments Ltd. v. The Queen, 90 DTC 6556, [1990] 2 CTC 418 (FCTD)

In this connection the reader may be reminded that a seal "imports" both consideration and delivery: that is to say, where a contract is under seal it is not necessary to prove either consideration or the delivery of the contract, consideration not being necessary in the case of a contract under seal and delivery being presumed. But that is not to say that want of consideration may not be proved or that a deed or contract under seal may not be held in escrow. ... Whether it is one or the other requires consideration of the purpose of the prescription, the context within which it is deemed to apply and the general intendment of either Parliament or of its servant in imposing it. ...
EC decision

Rolka v. MNR, 62 DTC 1394, [1962] CTC 637 (Ex Ct)

In the result, therefore, only Item E remains for consideration. The appellant resides at Burlington, Ontario, and is president and general manager of Rolmac Construction Co. ... The question as to whether or not persons and/or corporations are dealing at arm’s length is a question of fact to be determined by a consideration of all the relevant facts and circumstances and the statutory provisions. ... Wright, who was a shareholder, director and secretary-treasurer, was called as a witness on behalf of the respondent, but gave no evidence which would suggest that he or the other shareholders in Nelmar at any time gave independent consideration to the purchase and sale of the properties. ...
FCTD

The Queen v. Wellburn, 95 DTC 5417, [1995] 2 CTC 196 (FCTD)

I may not fully comprehend what was contemplated when the learned Tax Court judge suggested such a view ’’would in some circumstances, such as those under consideration, render the limitation period devoid of meaningful substance”. ... Perri and Wellburn setting out a proposal for consideration by various creditors. ... Wellburn on January 15, 1987 asking for deferral of any action to proceed against the directors of Olympic while a recent proposal to creditors was under consideration. ...
FCTD

Alberta and Southern Gas Co. Ltd. v. The Queen, 76 DTC 6362, [1976] CTC 639 (FCTD), aff'd 77 DTC 5244 [1977] CTC 388 (FCA), aff'd 78 DTC 6566, [1978] CTC 780, [1979] 1 SCR 36

Accordingly consideration must first be given to whether the plaintiff falls within the definition of a “principal-business corporation” as set forth in subparagraph 66(15)(h)(i) as quoted above. ... The consideration which the plaintiff received under the agreements for its payments of the two amounts of $4,000,000 each was the conveyance from Amoco of its percentage of its interest in what is clearly a Canadian resource property in the hands of Amoco, the cost of which to the plaintiff is a Canadian exploration and development expense. ... Income arose from the 3% interest rate negotiated by the plaintiff and Amoco on the consideration paid by the plaintiff to Amoco. ...
FCTD

The Queen v. Roynat Ltd., 81 DTC 5072, [1981] CTC 93 (FCTD)

The guarantee itself contains the following recital: AND WHEREAS it was a condition precedent to the financing contained In and secured by the Trust Deed that the Guarantors further agree as hereinafter provided; and the following undertaking: NOW THEREFORE WITNESSETH, that in consideration of the sum of $1 and in consideration of the premises, the Guarantors hereby agree and undertake that in the event the Company does not have income available (as defined in the Trust Deed) for the payment of interest on such dates as called for on the repayment Schedule of the First Mortgage Income Bond then the Guarantors shall pay interest thereon at the rate of 8%% per annum. ... As in the case of another contract its validity depends upon the mutual assent of the parties to it, their capacity to contract; and consideration, actual or implied. ... Counsel also cited from Thorson, P’s judgment in the well-known case of MNP v James A Taylor, [1956] CTC 189; 56 DTC 1125, regarding some of the criteria to be taken into consideration when deciding whether a particular transaction constitutes an adventure in the nature of trade. ...
TCC

E. William Abrahamson v. Minister of National Revenue, 91 DTC 213, [1991] 1 CTC 2061 (TCC)

Random House Dictionary of the English Language superannuation... a pension or allowance to a superannuated person. pension... a fixed amount, other than wages, paid at regular intervals to a person or the person's surviving dependents in consideration of past services, age, merit, poverty, injury, loss sustained, etc.... a retirement pension. ... The Case plan and the IRA were different documents with different causes, considerations and objects. ... The term “pensions” referred to in Article VIA of this Convention means periodic payments made in consideration for services rendered or by way of compensation for injuries received. 8. ...

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