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In the case of a debt obligation, the corporation may, by filing a prescribed form, designate an amount up to the consideration for which the debt obligation was issued. Subsection 194(4) provides: 194(4) Every taxable Canadian corporation may, by filing a prescribed form with the Minister at any time on or before the last day of the month immediately following a month in which it issued a share or debt obligation or granted a right under a scientific research and experimental development financing contract (other than a share or debt obligation issued or a right granted before October, 1983, or a share in respect of which the corporation has, on or before that day, designated an amount under subsection 192(4)) designate, for the purposes of this Part and Part I, an amount in respect of that share, debt obligation or right not exceeding the amount by which (a) the amount of the consideration for which it was issued or granted, as the case may be, exceeds (b) in the case of a share, the amount of any assistance (other than an amount included in computing the scientific research and experimental development tax credit of a taxpayer in respect of that share) provided, or to be provided by a government, municipality or any other public authority in respect of, or for the acquisition of, that share. ... This question involves a consideration of section 166 of the Income Tax Act: 166. ...

He had nothing to do with running them. [20]          None of these considerations including the bank account and credit cards he had in Canada- and had to have because his family was living here- make him ordinarily resident here in 1992, 1993 and 1994. [21]          He did not in my view become a resident until 1995. ... The difference cannot be stated in precise and definite terms, but each case must be determined after all of the relevant factors are taken into consideration, but the foregoing indicates in a general way the essential difference. ... In successive years his residence there was in the regular routine of his life acting entirely upon his own choice, and when one takes into consideration these facts, particularly the purpose and object of his establishing that residence, the conclusion appear to be unavoidable that within the meaning of this statute he is one who is ordinarily resident at East Riverside, New Brunswick, and is therefore liable for income tax under section 9(a). ...

(l) the agreeing to provide, or the arranging for, a service referred to in any of paragraphs (a) to (i), or (m) a prescribed service, but does not include (n) the payment or receipt of money as consideration for the supply of property other than a financial instrument or of a service other than a financial service,... ... Generally speaking, the amount which the recipient of a service repays to the supplier for costs incurred in making the supply is deemed to be part of the consideration for the supply. ... In consideration of this service, Skylink charges the amount of $15, which roughly corresponds to the discount deducted when the credit card slip is submitted to the issuer. ...

In my opinion, the expression “one or more transactions’’ in Section 8(3) is wide enough to embrace all types of voluntary processes or acts by which property of one person may become vested in another without regard for the reason or occasion for such processes or acts and regardless also of whether the process is undertaken or the act is done for consideration in whole or in part or for no consideration at all. ... But these considerations do not conclude the matter. The three shareholders, in determining to wind up the company, had a common purpose to get rid of certain difficulties which were being encountered in connection with the company by winding it up and, at the same time, having a new company take over its undertaking. ...

Duthie had also consulted with his accountants as to, amongst other things, the way in which to deal with some tax considerations. ... This is confirmed by facts such as Duthie’s call for proposals from project managers, the selection of project manager, the submission of a contract by the architect, that John Duthie quit his job in Edmonton to move to Invermere and consideration of condominium unit sizes. ... In this case, these arrangements were not linked to exploratory considerations, but to actual development activity. ...

It is a finding of fact to be made taking into consideration the criteria mentioned in the Moldowan case but the criteria mentioned were not intended to be exhaustive. ... With these considerations in mind it is expedient to again reproduce the first two of the three classes of farmers whom Mr Justice Dickson said the Income Tax envisioned and his comment thereon. ... In seeking an answer, gross income, net income, capital investment, cash flow, personal involvement, and other factors may be relevant considerations. ...

However, I find no definite evidence of the petitioner giving consideration to the possibility of an issue with the Department in relation to these matters before October, 1977. The documents, and particularly a privileged memorandum of October 3, 1977, make it clear that, by that time, active consideration was being given to the income tax implications of the inter-company dealings. ... I find no evidence that it was sent because of any legal considerations or that it was sent to Mr Clark in his capacity as legal adviser. ...

The consideration for that option was a payment by the defendant of $250,000. ... We shall have the right at any time prior to receipt of your notice, to notify you in writing that we elect to cancel the rights granted you in our letter of April 6, 1979 in consideration of the sum of TWO HUNDRED AND FIFTY THOUSAND DOLLARS ($250,000.). ... The money received by the defendant, whether it is termed an indemnity or a buy-out or monetary consideration to cancel whatever rights it might have acquired from Mirlaw Investments Ltd. came out of a single transaction involving a non-resident of Canada and, in accordance with the Tax Convention, does not attract tax liability. 4. ...

They signed a contract with the appellant to develop the lot, or part thereof, by planting and growing trees with a view to cutting them and marketing the timber. [5]      As an example, in consideration of the sum of $10,000, the appellant offered an investor a lot or part thereof, along with the right to plant 100 teak trees on the lot, for $100, which is 1% of the amount of the investment. In a separate contract, the appellant obtained a mandate to develop the lot and plant trees on it in consideration of $9,900, which is 99% of the amount of the investment. ... It states that the determination of the place where a business or part thereof is carried on necessarily requires a consideration of all relevant facts but has been stated in general terms to be the place where the operations in substance take place. ...

On September 30, 1985 pursuant to a transfer of land (Exhibit R-7), for which the consideration was the sum of $68,000 a Certificate of Title (Exhibit R-8) was issued in the names of Richard George Wassick and Sharon Anne Ferguson — now his common-law wife and the mother of his child — as joint tenants to certain property in Nelson. This is the same property which was the subject of a transfer of land (Exhibit R-9), dated December 16, 1986 from the appellant and Sharon Ferguson as joint tenants to Sharon Ferguson, in consideration of the sum of one dollar. ... The difference cannot be stated in precise and definite terms, out each case must be determined after all of the relevant factors are taken into consideration, but the foregoing indicates in a general way the essential difference. ...