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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. ...

The appellant also guaranteed loans made by the CIBC to Beeandee without any consideration from Beeandee. ... The same considerations apply to shareholder guarantees for loans made to corporations. ... Steer, [1967] S.C.R. 34, it was held that a guarantee given to a bank for a company's indebtedness by the taxpayer in consideration for shares in the company was to be treated as a deferred loan to the company and that monies paid to discharge that indebtedness were to be treated as a capital loss. ...

He did not make any agreement with Cloud 9 before guaranteeing the loans and it was his position that no consideration passed. ... M.N.R., 90 DTC 1068 in support of her position that there was no consideration for the loans and that it was merely wishful thinking that they might make a profit. ... There was no consideration made for the loans. [134] Further, counsel argued that the amount owing to Cloud 9 was a capital outlay only and was not deductible by the Appellants as they sought to do here. ...

This kind of document is merely a means of recording a liability; it is not itself evidence of the passing of goods or services or consideration which created or gave rise to the liability. ... Otte   (To be determined)     (To be determined)       (18,315.68) Less consideration paid by Mr. ... Otte and his sons formed part of the consideration provided by Mr. and Mrs. ...

The fact is that the Appellant never owned or operated any kind of business at all during the taxation period under consideration. ... This subsection must be applied subjectively to the taxpayer, taking into consideration the intelligence, education, experience, etc. of the taxpayer. ... FA convinced the taxpayers to become involved in a scam identical to the one here under consideration. ...

The commercial profit to the appellants on the investment in NAM LLC, excluding Canadian tax considerations, was US$1,254,674. ...   [62]         However, the purpose of a transaction is a question of fact, and one to be made on a consideration of all of the circumstances surrounding the transaction. ... As I indicated earlier in these reasons, the purpose of a transaction is a question of fact, and one to be determined on a consideration of all relevant circumstances. ...

The test for appellate review of the exercise of judicial discretion is whether the judge at first instance has given weight to all relevant considerations. ... Although it is quasi-judicial discretion, the discretion must still demonstrate that it did take into account, thus, did weigh all relevant considerations. ... The standard of correctness may nevertheless be coupled with a reasonableness component in respect of the decision as to the consideration of the Letter of Credit in question.   ...

However, this approach has the advantage that it preserves the ability to deal appropriately with future cases which present considerations not previously apparent. ... The same would be true of any consideration of the weight, if any, to be given to the residence [page898] of the appellant upon receipt of the benefits as this was also on the reserve.   ... [Emphasis mine]      In light of the considerations to be applied to these findings, including the purpose of the exemption under the Indian Act, it is apparent that the type of property in question, is not meant to be protected from the taxation in question.  ...

The like considerations apply to sections 7 and 8 of the Statute of 1924 respecting the Revised Statutes. ... In accordance with the agreement inter partes, we confine our consideration of respondents’ liability to the year 1930. ... This argument requires the consideration of other matters. Schedule A to the Commissioners’ Roll already mentioned appears at the end of Volume IV of the Revised Statutes of 1927, and under the heading “1926” in the three columns headed respectively “Chap.”, “Title of Act” and “Extent of Repeal,” appear the following:— 10. ...

Un second point concernait un paiement reçu en 1963 par l’intimé en considération de son intérêt dans l’ancienne étude d’avocats. ... Section 4 defining income from a business or property as “the profit therefrom” would appear to negate the consideration of losses. ... It was obviously drawn up with great care and special consideration was given to the fiscal consequences of the provisions for payments to a withdrawing partner or to the estate of a deceased partner. ...