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The corporation could designate an amount up to 100% of the consideration it had received on the issuance of the security, and 50% of the amount so designated became a corporate-purchaser's S.R.T.C. deductible by it from its tax otherwise payable for the year or the previous year. ... (the company), in consideration of the payment of $200,000 by United Equities, issued a debenture in the amount of $114,000 to the plaintiff in accord with an agreement dated May 28, 1984. ... These considerations, in the submission of the defendant, and the fact that the letter referred to 30 days, not to 90 days as the statute provided for compliance, meant that the letter did not constitute notice within subsection 194(7). ...

It follows that such decision-makers will generally be entitled to some degree of curial deference. [58]            The third factor requires consideration of the purpose of the legislation, and the purpose of the particular provision in question. ... However, the specific administrative decision at issue in this case does not engage policy issues, or require the balancing of multiple sets of interests and considerations. ... Anderson asked for consideration on the basis that he otherwise met the pre-requisites by virtue of the length of his service, the fact he had worked at a level higher than PM-02, and by his work on the CCRA transition team. ...

Nelson without adequate consideration (Affidavit of Michael Sundstrom, paras16-17) ... Nelson transferred the sum of $33,485 to the Company for no apparent consideration. ... The McCulloch Property has been the subject of several non-arm’s length transfers for no, or inadequate consideration. ...

They claim he followed the policy’s direction not to reassess a statute-barred return if the request is made as a result of a court decision as a complete bar to the Applicants’ relief requests, ignoring other relevant considerations. ... The record shows that this consideration was the primary, and in reality probably only, reason for the denial of reassessment of Ms. ... However, the reassessment provisions are discretionary in nature and strict policy adherence to refuse an adjustment related to an adverse court decision without proper consideration of the specific circumstances of the request would be an inappropriate use of discretion. ...

Lastly, I will address the policy considerations raised by the Bank. A.   ... Weisflock in consideration for the transfer of his house to a third party constituted “proceeds” of property that was the subject matter of the deemed trust. ... Policy Considerations [58]   The Bank also raised a number of arguments that may be classified as policy or fairness arguments. ...

Counsel for the plaintiff argues that the dividend payment to Ruby Neuman was an attempt at tax avoidance (income splitting) and not the product of a business arrangement made for adequate consideration. ... The determination of law applicable to the case at bar requires a consideration of the findings of the Supreme Court in McClurg. ... In my view, the reference to “quid pro quo" is related to the qualification that for subsection 56(2) to be applicable, a payment made must be a "benefit" and not a payment for adequate consideration. ...

As noted above, the Memorandum prepared for the Minister’s consideration laid out the fairness arguments in a more expansive way than in the Applicant’s request for a remission to the Assistant Commissioner or in his direct request to the Minister. [70] The Memorandum also describes the circumstances and relevant considerations that may warrant a recommendation for remission. ... The Memorandum also explained the public interest considerations. [71] The Court does not agree that Barrs and Mockryke show the court’s openness to softening the principle that remission decisions are highly discretionary and that remission is not an extraordinary remedy. [72] In Barrs, the Federal Court of Appeal allowed the appeal of the Federal Court’s dismissal of Mr. ... The Minister did not fail to grapple with the Applicant’s submissions or the relevant considerations, including those set out in the FAA. ...

They also address the factors and considerations set out in Part II of the CRA’s Information Circular IC07-1R1, Taxpayer Relief Provisions, August 18, 2017 [the Guidelines] and makes recommendations. ... By referencing consideration of “other circumstances,” the Minister demonstrated that her consideration went beyond what the current Guidelines provide. [41] The Minister considered Mr. ... It is erroneous to state these considerations are limitations on the Minister’s discretion; rather, considering them ought to be properly understood as the Minister exercising her discretion and considering “other circumstances” not mentioned in the Guidelines. [42] Consideration of those circumstances may go to the reasonableness of the Decisions, but has no bearing on the manner in which the Minister conducted herself, given the absolute discretion she has in making these Decisions. ...

The scope of the subsection is not obscure for one does not speak of benefitting a person in the sense of the subsection by making a business contract with him for adequate consideration. ... But this right is subject, according to the generally accepted view, to the important qualification that a shareholder has, generally speaking, and subject to certain considerations which are discussed in the chapter on Dividends, no right to say when those profits shall be distributed, or, in other words, he has no right to demand the declaration of a dividend, that being a matter for the discretion of the directors, with which the Courts will not interfere unless in case of fraud or bad faith. ...

While those comments were made in the context of his general consideration of how severe the sentence should be, which included the option of imprisonment for the individuals, I recite them because they fairly summarize, in his own words, the position Judge Fairbanks expressed on conviction. ... Now having found that the assessment of the determination of fair market value is not satisfactory to me, the only evidence was the evidence of Mr Strung* [1] and he was evasive and I use that word not that strongly but he couldn’t or didn’t put a figure on what would be the assessment of fair market value assuming that he took into consideration the sale of this property. ...