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[Droit administratif, page 311, 4.02(62)] [Translation.] 4.03.8 The respondent refers to an argument made by the appellant to the effect that subsections 1100(11) to 1100(14) of the Regulations require that income from rental property be taken into consideration and that accordingly the deduction of capital cost allowance is subject to external factors which have nothing to do with the principles of depreciation of the cost of a property. ... Moreover, the fact that subsections 1100(11) to 1100(14) of the regulations require that the income from rental property be taken into consideration is in no way inconsistent with the delegation of powers provided in paragraphs 20(1)(a) and 221(1)(a) of the Act. ... Accordingly, the hotel contract may be defined as being the agreement between a businessperson, the hotel-keeper, and aconsumer, the traveller, under the terms of which this businessperson makes available to the traveller, for a certain time and for consideration, a furnished room, the opportunity to deposit his or her effects there, and a number of related services, inter alia restaurant services. ...

It follows that the consideration necessary to form a binding contract between the insured and the broker or agent is the acceptance by the former that a percentage, generally of the premium but occasionally of the sum insured or annuity consideration, will be paid by the third parties to that contract, the various insurers with whom the business is or will be placed. ... They represented the consideration in exchange for which the U.S. insurers agreed to underwrite the risks of the U.S. insureds. ... It is clear that the overriding consideration remains the lack of prejudice to the other party evidenced by the fact that all relevant evidence or material facts necessary to the application of the legal provision are on the record. ...

While that proposition might have merit in a consideration of a deduction claimed under paragraph 18(1)(a) of the Act, it is not the governing factor under paragraph 20(1)(l) of the Act. ... In either event, I find no basis for rejecting the claim based on the respondent’s argument that the loans were on capital account and therefore disqualified for consideration under section 20 of the Act. ... Nor was any consideration given to charging interest to the subsidiary on advances made by the respondent. ...

Entitlement to ITCs under section 169 was under consideration. ITCs are limited to tax paid on property or services acquired “for consumption, use or supply in the course of commercial activities”. ... In the latter two cases, the Tax Court highlighted the following factors when determining whether books and materials formed a single supply with the instructional services offered by the taxpayer: •        Whether a single price (covering books, supplies, and tuition) was advertised or whether each item was quoted separately (single price suggests single supply); •        Whether a student reviewing the promotional literature would view the price as a single consideration for a course of instruction, or whether the student would think that they were paying several considerations for books, tuition, etc. ... The statutory provision under consideration sets out a rule to determine a taxpayer’s capital gain from the disposition of property and only expenses or outlays to be applied in reducing the gains are those incurred or made directly for the purposes of making the disposition. ”   [21]        See Imperial Oil Ltd. v Minister of National Revenue, [1948] 1 D.L.R. 305 at 319-323 ...

Since the consumer is not a registrant, this right cannot be assigned or transferred to the appellant, which paid the cost of the replacement vehicle in place of the consumer. [107]    Where a person, in consideration of a sum of money, decides to formally make undertakings that are likely to occur in the event of a total or partial loss of property, that person cannot claim to have suffered harm after the fact if the expected assumptions have changed. That is the very essence of a contract whose consideration is the assumption of any risk. [108]    In this case, the purchaser of the taxable supply is not the appellant but the consumer, who benefits from the reimbursement contract for the entire price that he obtained from the appellant through a premium. [109]    Who received the supply? ... In other words, the consideration for the time spent on preparing the claim, as important as it is, is more than offset by the sale of a new vehicle. [113]    Any person holding a protection plan in any field must provide notification, and prepare and submit a request for payment in the event that the risk anticipated by the plan occurs. ...

The problem is that these considerations do not connect the appellant's employment income to any particular reserve. ... These factors should then be analyzed to determine what weight they should be given in identifying the location of the property, in light of three considerations: (1) the purpose of the exemption under the Indian Act; (2) the type of property in question; and (3) the nature of the taxation of that property. ... In the context of the exemption from taxation in the Indian Act, there are three important considerations: the purpose of the exemption; the character of the property in question; and the incidence of taxation upon that property. ...

Under the circumstances, the Revenue Quebec sample was not proportional to the relationship between evenings with a show and evenings without a show, whereas this is an essential consideration.   33. ... The relevance of the expert witness is clearer when the many faults revealed are taken into consideration.   59. ... In fact, the appellant received consideration for this by benefitting from publicity in the Grayline fliers. ...

The Appellant provided no consideration for these payments by his son, and is not challenging the assessment as such. ... With respect to the commissions, the letter states that an investigation disclosed that the commission was not $80,000, but $100,000, and was paid to Alain Vaillancourt in shares in consideration of his involvement. ... Counsel repeated that this commission followed a major sale of a block of shares by Éric Dupont in consideration of the commission. ...

Three issues merit consideration. [3]      Firstly, the engagement of the Intervener is argued to have been assumed by a Mr. ... For good consideration, the Company employs the Employee on the following terms and conditions.   2.     ... It was drawn from her Canadian chequing account in consideration for services performed by the Intervener during the month of July 2004. ...

Klassen stated that in the Saskatoon office the practice utilized is to refer to section 251 of the Income Tax Act which defines relationships and to then refer to section 69 of the Income Tax Act which deals with inadequate considerations of various sorts occurring in transactions between persons dealing with each other non-arm's length. ... On the other hand, when the Minister is required by the legislation to be "satisfied" that a certain situation existed which will- in effect- "undeem" that which has been deemed- no mean feat in itself- different considerations apply and it would be useful to have some insight into the process utilized by the Minister. ... It is apparent in her testimony that the overarching purpose of the Act is to regard the employment of related persons as being included in insurable employment provided the work was legitimately performed and there is no evidence of fraud or transactions fraught with inadequate considerations as outlined in some detail in section 69- and 14 subsections- of the Income Tax Act. ...