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No exhaustive list has been compiled and perhaps no exhaustive list can be compiled of considerations which are relevant in determining that question, nor can strict rules be laid down as to the relative weight which the various considerations should carry in particular cases. ...

The provisions of the Excise Tax Act relevant to these appeals are as follows: 123(1) In section 121, this Part and Schedules V to X, "supply" means, subject to sections 133 and 134, the provision of property or a service in any manner, including sale, transfer, barter, exchange, license, rental, lease, gift or disposition. 165(1) Subject to this Part, every recipient of a taxable supply made in Canada shall pay to Her Majesty in right of Canada tax in respect of the supply calculated at the rate of 7% on the value of the consideration for the supply. 177(1) Where (a)         a person (in this subsection referred to as the "principal")makes a supply (other than by exempt or zero-rated supply) of tangible personal property to a recipient (otherwise than by auction), (b)         the principal is not required to collect tax in respect of the supply except as provided in this subsection, and (c)         a registrant (in this subsection referred to as the "agent"), in the course of a commercial activity of the agent, acts as agent in making the supply on behalf of the principal, the following rules apply:             (d)        ... ... That is perfectly logical respecting an agent who has possession of the goods and receives the payment of consideration for the sale of goods. ...

No exhaustive list has been compiled and perhaps no exhaustive list can be compiled of considerations which are relevant in determining that question, nor can strict rules be laid down as to the relative weight which the various considerations should carry in particular cases. ...

I shall deal further with this point below. [5]      In October 1991, the appellant purchased from Irene Jarawan the restaurant business known as Queen Isabella Restaurantfor $110,000. [6]      The parties agreed that the purchase price would be apportioned as follows:           chattels, equipment, functions and trade fixtures       $50,000           goodwill                                                                 $40,000           leasehold improvements                                          $20,000 Additional consideration for the stock in trade was to be ascertained by a determination of the cost price. [7]      With his 1994 return of income the appellant filed a T-664 form (Capital Gain Election) in which he elected that the provisions of subsection 110.6(19) of the Act should apply to the goodwill. ... It incurred a loss of $ (18,985) in 1992 and marginal net income of $6,714, $5,495 and $2,890 in 1993, 1994 and 1995 before any management remuneration and income taxes considerations. ...

Now therefore, for and in consideration of the mutual promise, covenants and agreements herein set forth and other good valuable consideration, the receipt and sufficiency of which are hereby acknowledged, the parties hereto agree as follows:        I.     ...

This second branch as described by the Court of Appeal is open to consideration of any number of examples including those I have cited. ... In some instances such permissiveness will afford a consideration of the likely reliability of certain evidence versus the cost of bringing better evidence to the court ...

With respect to financial risk, I respectfully agree with my colleagues that the appellant in consideration for a higher pay gave up many of the benefits which usually accrue to an employee including job security. ... There was no arrangement concerning overtime payments, health insurance coverage, or pension plan considerations. [21]     All of the above favours the appearance of a relationship of independence between the Appellant and the workers. [22]     The question of "whose business is it? ...

Subparagraph 7(f) of the Reply reads as follows: [translation] (f)          The Minister determined that the sum of $10,000 was received in consideration for the non-performance of a contract for services and treated it as "other income"; According to paragraph 11 of the Reply, [translation] "the sum of $10,000 was correctly included in the calculation of the Appellant's income, as "Other income", under sections 3 and 5 of the Act. ... He sometimes described it as being [translation] "in consideration for the non-performance of a contract for services" and as [translation] "Other income," under sections 3 and 5 of the Act (refer to subparagraph 7(f) and to paragraph 11 of the Reply to the Notice of Appeal), sometimes as income from a business, under subsection 9(1) and section 3 of the Act (refer to the Notice of Confirmation, Exhibit I-5). ...

The Scheme participant’s payment of $20 of his own money is made in consideration for the Scheme participant’s receipt of a 25-year interest‑free loan and a charitable tax receipt in the amount of 5 times the actual cash payment.   3.        ... Gould’s cash payments of $100,000, $20,000 and $10,000 (i.e. 20% of his total alleged donation) in his 2000, 2001 and 2002 taxation years, respectively were paid to Ideas in consideration for his receiving charitable tax receipts in the amounts of $500,000, $100,000 and $50,000, respectively.   5.        ...

At issue is the reasonableness of the consideration that was paid by the Appellant to the affiliates for ranitidine. The Minister of National Revenue says that the consideration was not reasonable in the circumstances, and has assessed accordingly. ...