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The appellant’s transactions had real economic substance: the common shares of Rcongold were transferred to the PCT for a real consideration after a dividend was in fact paid by the issuance of preferred shares. ...   [56]          A contextual and purposive reading of sections 3, 38 (more specifically paragraph 38(b)), 39 and 40 must take into consideration their legislative history and context and their interplay with subparagraph 40(2)(g)(i), section 54, former subsection 55(1) and section 251.1. ... The amendments were aimed primarily at disallowing losses on transactions carried out between related persons through the use of a trust, which transactions previously circumvented the anti‑capital gain stripping tax policy considerations underlying, inter alia, subparagraph 40(2)(g)(i). ...

Pagé subsequently received the return of $5,000, in consideration of which he sold his interest in Mini‑Robots ... Technik, which, in consideration of the transfer, cancelled the loan and the interest thereon ... Toutounji's case, this return was made on June 1, 1993, and was in consideration of the transfer, by Mr.  ...

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. ... None of the normal commercial considerations were given to collecting the debt from the partners. ... Family considerations played a key role. She wanted to assist Glenwood in which shareholding her husband owned a third interest. ...

This is an irrelevant consideration that he took into account and we are not sure that it did not affect or colour his decision ... Whether this consideration influenced Beaubier J. is something that I need not determine. ... In some cases the nature of the work itself may be an important consideration.               ...

This four-in-one test involves a consideration of (1) control; (2) ownership of tools; (3) chance of profit; and (4) risk of loss. ... A consideration of this factor indicates that the workers were independent contractors and contra-indicates an employer-employee relationship. ... A consideration of this factor tends to indicate that the relationship was that of an employer-employee and tends to contra‑indicate that it was that of an independent contractor. ...

]   (3)        Justice Martineau doubted the relevance of similar cases on which the Agency relied in suspending its consideration of the fairness case after Mr.  ...   [47]            My final comments about these considerations are that Mr.  ...   [57]            Fifthly, throughout the delegate’s analysis, there is a persistent ambiguity as to whether the delegate was taking both components of the applicant’s July 2001 fairness request into consideration. ...

Legislation [22]            In consideration of the request, the Minister referred to s 220(3.1) of the Income Tax Act, RSC, 1985, c 1 (5th Supp) [ITA], which provided situations under which relief could be granted. ... The refusal of interest relief is inconsistent with the spirit of taxpayer relief provisions and undermines the fairness process. [58]            The Applicant also argues that the Minister’s consideration of extraordinary circumstances was limited to the examples in the Guidelines. ... Respondent (1)                Considerations of the Minister [69]            The Respondent submits that the Decision is reasonable in light of the information before the Minister. [70]            Section 220(3.1) of the ITA allows the Minister a broad discretion to waive or cancel penalties and interest, which is guided by CRA guidelines. ...

The fair market value of the property received by the appellant on or about January 14, 1988 from the Estate of Benoît Montreuil was equal to $70,000 and no consideration was granted by the appellant. 8. ... They merely crystallise particular factors which may incline the scale in a particular case after a balance of all the considerations has been taken. ... Montreuil’s death in consideration of a full and final discharge. [Translation.] ...

My review of these assessable services took into consideration the size of the documents that were read and/or prepared and any related work that may have been required by the Respondent. ... My review of this assessable service took into consideration the size of the Appeal Book and the time that may have been required to verify the correctness of the documents included in within it. ...

The Appellant submits that these factors should be taken into consideration when determining the amount of costs to be awarded. ... Paragraph 147(3)a) specifically provides that the result of a proceeding may be taken into consideration by this Court. Therefore, at this stage of the analysis, the degree of success of a party is a factor that may be taken into consideration. ...