Search - consideration

Canada Cycle & Motor Co. has its own offices and manufacturing plant in the Town of Weston, and the shares that appellant holds in that company were acquired as the consideration, or part of the consideration, for the sale by appellant of that manufacturing business to Can. ... Appellant did not ask to be allowed to have the matter sent back for consideration of this question by the Board. ... With respect to appellant’s second contention, to which alone the Municipal Board gave consideration, the finding of the Municipal Board with respect to the carrying on of a business is that "Appellant Company was not carrying on a business within the meaning of s. 8 of the Assessment Act at the offices mentioned.’’ ...

We conclude that the amounts handed over to the Société (Appellant) by the AMT are not consideration for a supply. ... Therefore, the issue in this regard is only whether the subsidies paid to the Appellant were or were not "consideration" within the meaning of the ETA. ... It can therefore be concluded that the subsidies so paid were "consideration". ...

The following day Stephens entered into a similar agreement in respect of his option to purchase 10,000 common shares of MEPC Canada, for an aggregte consideration of $64,000. ... What is taxable under paragraph 7(l)(b) is the “benefit equal to the value of the consideration for the disposition”. ... Those words appear to me to be sufficiently broad as to include an amount received as consideration for the surrender of rights that are thereby extinguished,* [2] in contrast with an amount received as consideration for rights that are “transferred” and, as such, that remain in existence. ...

As reflected in Schedule "A" to the agreement referred to in paragraph 2 above, before the Trade Marks were assigned to [the Appellant], Underwriters first assigned them to its affiliate NN Life Insurance Company of Canada ("NN Life") "in consideration of One Dollar ($1.00) and other good and valuable consideration" on May 18, 1999. ... To the contrary, it states that the consideration paid by NN Life was "One dollar ($1.00) and other good and valuable consideration."" [14]     The consideration paid by NN Life to Underwriters, however, is referred to in the T2057. ...

To rebut this presumption, that the payment is to be treated as remuneration, the taxpayer must establish that the amount could not reasonably be regarded as one of three things: 6(3)(c) consideration or partial consideration for accepting the office or entering into the contract of employment; 6(3)(d) remuneration or partial remuneration for services as an officer or under the contract of employment; 6(3)(e) in consideration or partial consideration for a covenant with reference to what the officer or employee is, or is not, to do before or after the termination of the employment. ... Distinguishing this case from Phaneuf, there was no element of gift, personal bounty or of considerations extraneous to Mrs. ... But more importantly, the payment of the allowance with which I am concerned was primarily motivated by considerations extraneous to the employment, namely public and labour relations considerations. ...

Under the service agreement, the consideration to the appellant was the assignment of the promissory notes delivered to No. 624 by the investors as part of the purchase price. ... This is puzzling because the notes were assigned to the appellant on December 30, 1983 under the three service agreements as consideration (i.e. revenue) for services to be rendered. ... Therefore, I conclude that the appellant earned in each year one tenth of the aggregate consideration payable to the appellant under the service agreements. ...

"   [32]          I find it very difficult to accept that the payments contemplated in the service agreements entered into by the Bouchard family can be considered to have been received in consideration of the disposition of the clientele that was under their management as part of their employment with NBF, or in consideration of the disposition of some right of management in respect of that clientele ...   [34]          Since the agreements involved contain covenants not to solicit clients under the Appellants' management, as well as covenants not to compete with NBF, we must consider whether the amounts paid to the Appellants constitute consideration or partial consideration for those commitments, as opposed to consideration for a sale of assets ... (e)     in consideration or partial consideration for a covenant with reference to what the officer or employee is, or is not, to do before or after the termination of the employment ...

They were not thresholds to be satisfied; rather, the immigration officer examined and weighed all relevant H&C considerations. ... Canada (Minister of Citizenship and Immigration), [1999] 2 SCR 817, the Supreme Court stated: 75        The certified question asks whether the best interests of children must be a primary consideration when assessing an applicant under s. 114(2) and the Regulations.  ... That is not to say that children’s best interests must always outweigh other considerations, or that there will not be other reasons for denying an H & C claim even when children’s interests are given this consideration.  ...

Gough, however, took into consideration two factors to which he attributed great importance. ... Gough did take into consideration w hich I think on the evidence had no place in a computation based on ‘‘replacement value’’. ... The stated profit ratio would have been even higher had not the summary taken into consideration some losses on resales. ...

The appellant testified that the fees thus paid were in part consideration for the provision of guarantees as contemplated by the agreement between him ana Horaceville. ... In those returns Horaceville included under the heading “other income" the amounts said to have been in part management fees and in part consideration for the guarantees. ... In consideration payments by the appellant to the bank totalling $95,000 were to be made and other property was to be transferred. ...