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FCA

Canadian Magen David Adom for Israel v. Canada (Minister of National Revenue), 2002 DTC 7353, 2002 FCA 323

One is that it was based on irrelevant considerations. It is not for the Court to speculate as to what decision the Minister would have come to, had he taken account only of relevant considerations. ... Ontario (Liquor Licence Board) (1974), 5 O.R. (2d) 124 at 132-133: In the result, with respect to the November 30, 1973 decision, I have found that one of the reasons was based on an extraneous consideration, one either reflects an extraneous consideration or alternatively lacks any evidence in support of it and the third is relevant and there is some evidence on which it could be found. ... In my opinion, the Minister exercised his discretion to revoke, taking into account irrelevant considerations and, in the course of reaching his decision, denied the appellant procedural fairness. ...
FCTD

384238 Ontario Ltd. v. The Queen, [1981] CTC 295, 81 DTC 5215 (FCTD), aff'd 84 DTC 6101 (FCA)

It is further alleged that the chattel mortgage between Emily Allen and Ken Allen and Sons Limited in 1976 was a fraudulent conveyance for the purpose of defrauding creditors of Ken Allen and Sons Limited, no consideration having been given by her for it and that it was granted to her to transfer the ownership of the assets to defraud creditors. ... It is not even necessary to establish that the transfers were made with intent to defraud creditors in order to find that Mrs Alien’s title to the assets was defective for want of consideration. ... Section 2 does not apply to an estate or interest in real property or personal property conveyed upon good consideration and bona fide to a person not having at the time of the conveyance to him notice or knowledge of the intent set forth in that section. ...
FCTD

International Nickel Co. of Canada Ltd. v. MNR, 71 DTC 5332, [1971] CTC 604 (FCTD)

This consideration alone would, I think, dispose of any suggestion that the word “development” should be understood in any restricted sense but there is a further contrary intention to be found in section. ... F.C. of Taxation (1938), 61 C.L.R. 337; 5 A.T.D. 87, Recurrence is not a test; it is no more than a consideration the weight of which depends on the nature of the expenditure. ... One consideration may point so clearly that it dominates other and vaguer indications in the contrary direction. ...
FCA

Loewen v. The Queen, 94 DTC 6265, [1994] 2 CTC 75 (FCA)

The considerations prompting the transaction may be of such a business nature as to invest it with the character of an adventure in the nature of trade even without any intention of making a profit on the sale of the purchased commodity. ... This enquiry may or may not involve or necessitate a consideration of the profitability of a transaction or of the tax results of a transaction. ... In other cases, however, it happens that all of the historical criteria or principles relied upon to make a finding one way or the other are in a conflict situation, effectively resulting in a balance of considerations. ...
FCA

Opportunities for the Disabled Foundation v. Canada (National Revenue), 2016 FCA 94

Additionally, this Court found that where subsection 165(3) is in play, potential concerns with respect to the timeliness of the Minister’s consideration of a notice of objection can be addressed by the exercise of the appeal right that is available to the taxpayer on the 91st day after the filing of the notice of objection. ... The Appellant tendered no evidence to suggest that the Appeal Division of the CRA was tardy in its consideration of the Notice of Objection or that it would not have varied, vacated or confirmed the Revocation Proposal within a reasonable time. ... In the absence of detailed argument from either the Appellant or the Crown, I would leave the interpretation of the term “related business” for another day. [66]            The Appellant has not demonstrated that it was unreasonable for the Minister to have determined that the Appellant’s extensive fundraising activities in the period under consideration meant that it was not devoting all of its resources to charitable purposes and to have based the Revocation Proposal on that determination. ...
TCC

Duguay v. The Queen, docket 94-1081-IT-G

For 1989, he noted that 39 receipts had been issued for a total of $215,895 and that the consideration shown in the financial statements was $10,020, or four percent of the amounts shown on the receipts. ... In the case at bar, the evidence is clear that neither of the appellants received any consideration whatsoever from the organizations to which the property was given. ... A receipt obtained from the recipient organization cannot be viewed as consideration even though the taxpayer must file the receipt to be entitled to the deduction for gifts. ...
TCC

Langlois v. The Queen, docket 92-1124-IT-G

For 1989, he noted that 39 receipts had been issued for a total of $215,895 and that the consideration shown in the financial statements was $10,020, or four percent of the amounts shown on the receipts. ... In the case at bar, the evidence is clear that the appellant received no consideration whatsoever from the organization to which the property was to be given. ... A receipt obtained from the recipient organization cannot be viewed as consideration even though the taxpayer must file the receipt to be entitled to the deduction for gifts. ...
TCC

507582 B.C. LTD. v. The Queen, 2008 TCC 220

  [60]     The consideration for the transfer of the property was $1. ...   [74]     Further, the Goods and Services Tax (“GST”) is payable on the $1 fair market value of the consideration payable by Mrs. ... Krmpotic for the $1 consideration and the beneficial ownership of the property remained with the Company. ...
TCC

Hewlett Packard (Canada) Ltd. v. The Queen, 2003 TCC 386

The plaintiff acquired a vehicle and as part of the consideration the defendant accepted a trade-in of two vehicles. ... It applied the guidelines to get to that result and ignored terms of the agreement and circumstances and conduct that would suggest the property passed when ownership papers were transferred and consideration was paid. ... Accordingly, I was left on my own with the task of determining whether Quebec law required different considerations. ...
FCTD

Burstyn v. Canada (Canada Customs and Revenue Agency), 2006 FC 744

By correspondence, dated August 25, 2005, the Director of the Windsor Tax Services Office acknowledged receipt of the August 11 th letter and stated: I have given careful consideration to the document [the reviewer] issued on August 8, 2005 clarifying her ITPR decision of March 10, 2005. ... He does not say that he was the person who made that decision. [52]       The correspondence of the director of the Windsor office, dated August 25, 2005, states that the director has given careful consideration to the August 8 th clarification with respect to the ITPR decision of March 10, 2005. ... Program Components (Delegation and Accountability; Staffing Plan; Staffing Processes; Recourse for Staffing; Special Considerations; Official Languages Requirements; Post-appointment Situations; Fraudulent Practices; Monitoring and Evaluation) Canada Customs and Revenue Agency Staffing Program 2.    ...

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