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Registrants are required to collect tax on the value of the consideration received for taxable supplies (subsection 221(1)), and they are generally entitled to ITCs for the tax paid on their purchases to manufacture those taxable supplies (subsection 169(1)). [33] Registrants are required to file GST/HST returns for each reporting period, which can be monthly, quarterly or yearly (subsection 238(1), section 245). ... The assessment requires the consideration of all the information, and grant the registrant the benefit of any new element that could reduce the tax owing. [61] In re-calculating and assessing the net tax, the Minister will consider all the information. ... At this point, the “ overpayment ” is inclusive of all ITCs and rebates that were originally claimed by the registrant, as well as those “ allowable credits” and “allowable rebates” “discovered” by the Minister during the assessment. [65] The Minister must then apply the overpayment (again after consideration, and taking into account any “allowable credit” and “allowable rebate”) against any amount owed by the registrant for the particular reporting period (paragraph 296(3)(a)); apply the overpayment that remains after consideration of paragraph 296(3)(a) against any other amount owed (paragraph 296(3)(b)); and refund any amount that remains under paragraph 296(3)(c) (instead of, potentially, apply the overpayment to future net tax amounts that could be owed). [66] However, paragraph 296(4)(b) then limits the refund of an overpayment resulting from the assessment (again including any “allowable credit,” but also any other ITC that has not yet been refunded and that result in an overpayment) to ITCs that would have been allowed had the ITCs been made on the date of the assessment. ...

It is not an amount paid as consideration for services rendered. The grantor of the bursary does not grant it in return for a consideration from which the grantor will benefit directly. ... This determination is to be made by the courts, taking into consideration the facts and, in particular, the parties' behaviour ... When a person is paid a salary, the salary is not financial aid, but consideration for services rendered by that person. ...

These considerations are not independent of one another and may overlap. ... To date, paragraph 96(1.01)(a) has not received judicial consideration. ... These facts lead me to conclude that the shares issued in the First Stock Dividend were redeemed for fair market consideration. ...

I will return to these special considerations when I analyse each element of the framework. [96]   A more general point should be made at this juncture. ... This will be useful for the third stage of the analysis, balance of convenience, where the strength of the plaintiff’s case is a relevant consideration. ... How this is to be reconciled with section 121 is, to my knowledge, an issue that has never received serious consideration. ...

The importance of these considerations was underscored by Jackett C.J. in his decision in Oryx Realty Corp. v. ... The importance of the "match" flows from the critical role timing considerations play in taxation matters. ... Both the application of subsection 10(1) as well as the definition of "inventory" must be very sensitive to these considerations. ...

I am satisfied that it is sufficiently accurate and precise for the consideration of the point to be decided. 2 The sinking fund requirements of the preferred share issue made it practically speaking impossible to float a bond issue. 3 *It is worth noting at this point that the $300,000 raised in 1956 by issuing common shares was also paid to redeem the. preferred shares so that, if the $400,000 of borrowed money was not being used in the business to earn income, neither was the $300,000 additional subscribed capital. ...

That conclusion was based on his consideration of the law of Canada and the facts he found on the evidence. ...

The relevant provisions of the contract under consideration in that case and those of the contract in issue before us are substantially the same. ...

Distinguishing this case from Phaneuf, there was no element of gift, personal bounty or of consideration extraneous to Mrs. ...

However, my consideration of the evidence leads me to conclude that Mr. ...