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The bookkeeper, Suzan DiMichele would go in the office once a week and also took care of the invoicing of the Payor at its office after the office workers were laid off work. [26] The Minister, according to the evidence, took into consideration the working arrangements and conditions of these Appellants. He analyzed the payroll, the work carried out by the Appellants, the seasonal type of business, the duties of the Appellants, the fact that two other shareholders, sometime in 1993, invested into the Payor, and the fact that the Insalaco members still owned two thirds of the Payor’s shares. [27] The Minister also took into consideration the wages that always remained the same for each respective Appellant before and after the arrival of the two new minority shareholders. ... On behalf of the appellant stress was also laid on the admitted fact that the consideration flowing from Orchan represented fair market value. ...

To this sum of $445,000 should be added the $10,000 deposited with the purchase offer and the transfer of the first mortgage debt amounting to $425,000, making a total of $880,000. [12] The contract itself indicated that the sale was made for a price of $1 and other good and valuable consideration as indicated in the offer of April 25, 1986. ... Charron who signed the notarial contract of June 2, 1986, in which it was mentioned that both the transferor and transferee set the value of the consideration for purposes of the transfer tax at $800,000. ... Charron who was initially assessed for this amount. [47] Cheque No. 1439 from the Servibec company, with the notations it contained, does however cast serious doubt on the statement that $1,000 bills were received in consideration, an initial clue tending to undermine the plausibility of the appellant's position. ...

  [35]     To defeat the assessment, the Appellant’s evidentiary task would be:  -          to establish the existence of the Partnership as a separate business entity; and  -          to refute that the cheques were merely “directed” to the Partnership but rather were paid to the Partnership as consideration for services provided by it pursuant to the contract ... Considerations for allowing amendments to pleadings have been considered by this Court and have not been necessarily altered by the introduction of subsection 152(9). [15]   [48]     The leading authority on whether or not an amendment should be allowed to save a defective pleading is Sweet. [16] In that case Justice Décary set out considerations for allowing amendments that have, as noted above, become known as the Sweet Factors. ... The overarching consideration must be whether the taxpayer knows the basis upon which they are being assessed so they may adduce the proper evidence to challenge the assessment. ...

Employee and shareholder benefits   (1) Employee and shareholder benefits               Where a registrant makes a supply (other than an exempt or zero-rated supply) of property or a service to an individual or a person related to the individual and   (a) an amount (in this subsection referred to as the “benefit amount”) in respect of the supply is required under paragraph 6(1)(a), (e), (k) or (l) or subsection 15(1) of the Income Tax Act to be included in computing the individual’s income for a taxation year of the individual, or (b) the supply relates to the use or operation of an automobile and an amount (in this subsection referred to as a “reimbursement”) is paid by the individual or a person related to the individual that reduces the amount in respect of the supply that would otherwise be required under paragraph 6(1)(e), (k) or (l) or subsection 15(1) of that Act to be so included,     the following rules apply:   (c) in the case of a supply of property otherwise than by way of sale, the use made by the registrant in so providing the property to the individual or person related to the individual is deemed, for the purposes of this Part, to be use in commercial activities of the registrant and, to the extent that the registrant acquired or imported the property or brought it into a participating province for the purpose of making that supply, the registrant is deemed, for the purposes of this Part, to have so acquired or imported the property or brought it into the province, as the case may be, for use in commercial activities of the registrant, and   (d)    in any case, except where (i) the registrant was, because of section 170, not entitled to claim an input tax credit in respect of the last acquisition, importation or bringing into a participating province of the property or service by the registrant, (ii) an election under subsection (2) by the registrant in respect of the property is in effect at the beginning of the taxation year, (iii) the registrant is an individual or a partnership and the property is a passenger vehicle or aircraft of the registrant that is not used by the registrant exclusively in commercial activities of the registrant, or (iv) the registrant is not an individual, a partnership or a financial institution and the property is a passenger vehicle or aircraft of the registrant that is not used by the registrant primarily in commercial activities of the registrant, for the purpose of determining the net tax of the registrant, (v) the total of the benefit amount and all reimbursements is deemed to be the total consideration payable in respect of the provision during the year of the property or service to the individual or person related to the individual, (vi) the tax calculated on the total consideration is deemed to be equal to (A) where the benefit amount is an amount that is or would, if the individual were an employee of the registrant and no reimbursements were paid, be required under paragraph 6(1)(k) or (l) of the Income Tax Act to be included in computing the individual’s income, the prescribed percentage of the total consideration, and (B) in any other case, the amount determined by the formula     (A/B) × C where   A is (I) where 1. the benefit amount is required to be included under paragraph 6(1)(a) or (e) of the Income Tax Act in computing the individual’s income from an office or employment and the last establishment of the employer at which the individual ordinarily worked or to which the individual ordinarily reported in the year in relation to that office or employment is located in a participating province, or 2. the benefit amount is required under subsection 15(1) of that Act to be included in computing the individual’s income and the individual is resident in a participating province at the end of the year, the total of 4% and the tax rate for the participating province, and (II) in any other case, 4%, B is the total of 100% and the percentage determined for A, and C is the total consideration.     ... Raymond is also responsible for increasing support payments to his former spouse to $2,750 per month, since the Court took into consideration, among other things, the cost of transportation (paragraphs 115 and 116, Exhibit A-8) ...

In fact, nothing seems to indicate that the legislator actually took it into consideration.... ... The promotion of equality entails the promotion of a society in which all are secure in the knowledge that they are recognized at law as human beings equally deserving of concern, respect and consideration.       ...

Deena Szostak, the Appellants, for the consideration of $195,000, strata lot 9 of the strata plan. ... This approach requires a consideration of the scheme as a whole, taking into account the intent of the legislation, its object and spirit and what it actually accomplishes. ... The first consideration should therefore be to determine the purpose of the legislation, whether as a whole or a expressed in a particular provision. ...

Lafond, with respect to the transaction in May 1993. [66] That being the case, the consideration given for the transaction should be looked at. ... In this regard, I consider it useful to point out that the consideration for the upstairs premises was $3.84 a square foot at the end of the lease in December 1990. [90] The rent for the ground floor was somewhere between $5.00 and $8.59 a square foot. ... He increased that price to $9.00 a square foot. [112] However, I do not think that the $8.59 figure, much less that of $9.00, is reliable; the fact that the consideration set out in the lease included all the equipment left there by the subtenant distorts the conclusion reached. [113] How should the actual value of the rent for the ground floor premises be determined? ...

Unquestionably, the amount received by the Appellant represented consideration for his services rendered as a solicitor. ... Among other considerations, Mr. Taylor never referred to such an arrangement. [51] I am fortified in this conclusion by the fact that when it was brought to his attention by Mr. ... Taylor in October 1991, I would be inclined to the view that it is improbable that the Appellant has only received $20,000.00 on account of the following considerations: 1. ...

Massey’s view, has the benefit of taking into consideration fluctuations in clientele. (4)    Auditor’s subsequent visit in March 2013 [40]         After completing her review, Ms.  ... 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.  ... In my opinion, the method the auditor chose has a significant weakness in that the 14‑inch boxes are not taken into consideration in the calculations. ...

  [45]         Legally, the recipient is the person who is liable to pay the consideration for the service under the agreement for the service (subsection 123(1) ETA and PDM Royalties Limited Partnership v. ... “recipient” of a supply of property or a service means   (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  ...   ...