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SCC

Western Leaseholds Limited v. Minister of National Revenue, [1959] CTC 531

The consideration for the purchase was the sum of $10,000 and the covenant of Mr. ... The expressed consideration payable by the lessees was the sum of $10, but as the evidence disclosed, the Barnsdall group paid to Leaseholds a further sum of $914,- 243.75 as consideration for the granting of the lease. ... The other considerations for the granting of the new lease are not relevant to the matters to be considered. ...
SCC

Judgment Accordingly. Western Leaseholds Limited v. Minister of National Revenue, [1959] CTC 530, [1959] DTC 1316

The consideration for the purchase was the sum of $10,000 and the covenant of Mr. ... The expressed consideration payable by the lessees was the sum of $10, but as the evidence disclosed, the Barnsdall group paid to Leaseholds a further sum of $914,- 243.75 as consideration for the granting of the lease. ... The other considerations for the granting of the new lease are not relevant to the matters to be considered. ...
TCC

Algoa Trust v. The Queen, 93 DTC 405, [1993] 1 CTC 2294 (TCC)

(b) Consideration for dividend A dividend is paid to shareholders for consideration, counsel submitted. ... This, too, is consideration given to the corporation in return for the dividend. ... Hence the appellants did not give consideration to Jaans for any dividend. ...
TCC

Global Cash Access (Canada) Inc. v. The Queen, 2012 TCC 173, rev'd in part 2013 FCA 269

The question is whether the fees are consideration for an exempt financial service provided by the casinos ... In general, if the portion of the consideration for the financial service is greater than 50 percent of the total, the entire consideration is exempt from GST on the basis that all services are deemed to be financial services.   ... The question is: What was provided by the Casinos in consideration for Casino Fees?   ...
TCC

Manship Holdings Ltd v. The Queen, 2009 TCC 75

  [4]               To the question of whether HST applied to that part of the consideration that the appellant allocated to the masseuses’ salaries, the answer was that the appellant had to collect HST in respect of the consideration paid, and the fact that the appellant allocated a portion of that consideration to its employees’ salaries was immaterial ... The services are rendered under a single contract, for a single consideration, albeit the invoice is itemized. ... Whether the services are rendered under a single contract, or for a single undivided consideration, are matters to be considered but are not conclusive. ...
FCTD

Duplessis v. Canada (Citizenship and Immigration), 2006 FC 1190

On May 28, 2013, the applicant filed an application for an exemption from the obligation to obtain a permanent resident visa from outside Canada based on humanitarian and compassionate considerations. ... In this case, the applicant submits that the immigration officer only examined the issue of whether she should grant or refuse an exemption for humanitarian and compassionate considerations based on the criteria set out above. ... The caselaw of this Court is consistent that an interview is not required to ensure procedural fairness in processing applications for visa exemptions for humanitarian considerations (see, for example Cheema (Litigation Guardian) v. ...
TCC

Scierie Landrienne Inc. v. R., [1998] 1 CTC 2066, 97 DTC 648

Lafontaine learned that this consideration could be “the extinction of an obligation”. ... The payment of an obligation, it was stated, cannot be a consideration for the party that pays. ... The fair market value of the first two parts of the consideration was not disputed. ...
EC decision

Falconbridge Nickel Mines Limited v. Minister of National Revenue, [1965] CTC 82, 65 DTC 5046

Such conclusion is reinforced by the presence of the words ‘‘in consideration for...” ... The consideration was ‘“shares’’ in Rambridge not ‘‘shares’’ in Rambler and not a “right to purchase shares’’ in Rambridge. Where under an agreement shares are the consideration, the person who makes the expenditure is entitled to the shares by virtue of the agreement. ...
FCTD

The Queen v. Zandstra, 74 DTC 6416, [1974] CTC 503 (FCTD)

Then in Black's Law Dictionary, revised 4th ed, 1968, West Publishing Co, 817 at 818 “gift” is defined as: A voluntary transfer of personal property without consideration. and: A parting by owner with property without pecuniary consideration.... ... A transfer of property in a thing, voluntarily and without any valuable consideration.... ... In all of those cases, the claim for gift was disallowed because of the presence of consideration for the payment. ...
EC decision

Consumers' Gas Co. v. MNR, 65 DTC 5138, [1965] CTC 225 (Ex Ct), briefly aff'd 67 DTC 5196 (SCC)

Limited (hereinafter called the ‘Underwriters’) the following amounts in consideration of the services rendered by the Underwriters as: hereinafter described: (a) $24,150 for services rendered by the Underwriters in forming and managing on Underwriting Group and Soliciting Dealers Group to facilitate subscriptions for the new common shares of the Appellant, and in consideration of the agreement by the Underwriters to use their best efforts to maintain an orderly market in the rights evidenced by the subscription warrants; (b) $108,315 representing commission payable to the Underwriters in consideration for their services as dealers in securities; and (c) $46 738.89 in consideration for the services of the Underwriters for the performance of all administrative and clerical work involved in processing warrants tendered by shareholders in the course of exercising their right to subscribe for and purchase the new common shares of the Appellant. ... The Appellant did not deduct the sum of $108,315 described in paragraph 5(b)..., such sum being regarded by the Appellant as a non-deductible commission payable to the Underwriters in consideration for their services as dealers in securities.” ... Amounts of $46,738.89 and $121,980 are claimed as deductible in sections 5(c) and 6(c) of the Notice of Appeal ‘‘in consideration for the services of the Underwriters for the performance of all administrative and clerical work involved in processing warrants tendered by shareholders in the course of exercising their rights to subscribe for and purchase the new common shares of the Appellant...’’ ...

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