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LEGAL OR CONTRACTUAL MATRIMONIAL BENEFITS: Mrs Veliotis specifically renounces all rights to the benefits stipulated In the marriage contract in her favour; in consideration of the settlement above provided for the said marriage contract to be annulled by the Ordinance of Divorce if and when rendered; with the exception of the furniture, which the Petitioner recognizes as the property of the respondent. ... The payments here under consideration are both assignable and Interest bearing under the terms of the second mortgage. ...

Jemp assigned to Petex in the 1962 calendar year all its interest in the letter of intent referred to in paragraph 4 hereof in consideration of Petex paying to Jemp a commission of $100,000 for its efforts in negotiating and obtaining the letter of intent from Texaco Exploration Company and Texaco Canada Limited which commission was to be paid out of the cash profits of Petex. The defence denies the allegations in paragraph 8 and says, inter alia, that during the 1961 or 1962 calendar year Jemp, on behalf of the defendant and other persons named, transferred to Petex its interest in the letter of intent and other assets for a consideration of $100,000 cash payable over a period of several years out of earnings by Petex plus 25% of the issued shares of Petex, and that the defendant’s interest in the letter of intent and other assets constituted his contribution towards the capitalization of Petex. ...

The relevant paragraphs of the letter read: If the final outcome of Peter Burnet's appeal from the assessment for the 1987 taxation year results in a loss, on account of income, on the disposition of the property (the “Property”) which was jointly owned by that person and the taxpayer, the taxpayer's share, whether it be one-half or otherwise as the case may be, of such loss would be taken into consideration in determining the taxpayer's non-capital loss for the 1987 taxation year and a Notice of Determination of such non-capital loss would be issued accordingly. However, even though the taxpayer may have a non-capital loss for the 1987 taxation year as referred to in the immediately preceding paragraph, the taxpayer's 1987 taxation year is statute-barred from re-assessment, and the taxpayer's share of any income loss on the disposition of the Property cannot be taken into consideration in computing her income, taxable income and tax payable for that year unless the Minister of National Revenue exercises his discretion to do so pursuant to the provisions of subsection 152(4.2) of the Income Tax Act. ...

Ultimately, the overriding consideration is that the best interests of justice be served (Canada (Attorney General) v Larkman, 2012 FCA 204 at paras 82, 85). ... While the Applicants’ case for an extension of time is not overwhelming, having considered the relevant factors together and taking into account the principle that the overriding consideration is that the best interests of justice be served, I am satisfied that extensions of time are warranted in the three proposed applications. [22] As such, my Order will grant the Applicants’ motions and afford each of the Applicants an extension of time to 30 days from the date of the Order to commence its application for judicial review. ...

Khan requested a second review, providing bank statements, tax forms, and Uber tax summaries for consideration. [10] On February 9, 2024, the CRA informed Mr. ... I do not find a reviewable error in the Officer’s decision. [18] The laws governing CERB, the CRB, and the CWLB do not allow for consideration of personal circumstances like illness or financial hardship when determining eligibility. ...

Paragraph 4 of the agreement provided for the interests the parties were entitled to receive thereunder on the following basis: each of the parties, except Tesluk, was to be entitled to receive 23.75% of the consideration, if any, received by the parties for their interest in any mining properties or claims acquired by the parties during the currency of the agreement. ... I quote the relevant portion of section 83 of the Act. 83 (1) In this section (c) “prospector” means an individual who prospects or explores for minerals or develops a property for minerals on behalf of himself, on behalf of himself and others or as an employee. (2) An amount that would otherwise be included in computing the income of an individual for a taxation year shall not be included in computing his income for the year if it is the consideration for (a) a mining property or interest therein acquired by him as a result of his efforts as a prospector either alone or with others, or (b)... unless it is an amount received by him in the year as or on account of a rent, royalty or similar payment. (3) An amount that would otherwise be included in computing the income for a taxation year of a person who has, either under an arrangement with the prospector made before the prospecting, exploration or development work or as employer of the prospector, advanced money for, or paid part or all of, the expenses of prospecting or exploring for minerals or of developing a property for minerals, shall not be included in computing his income for the year if it is the consideration for (a) an interest in a mining property acquired under the arrangement under which he made the advance or paid the expenses, or, if the prospector was his employee, acquired by him through the employee’s efforts, or (b).. unless it is an amount received by him in the year as or on account of a rent, royalty or similar payment. lt appears to be well settled that merely staking claims is not enough to constitute prospecting. ... There seems to have been a verbal understanding that payment of expenses by Tesluk along with legal services, would be the consideration for the interest (5%) given him by the agreement in the claims staked by the parties. ...

)       [36]       Section 34 adds special consideration because of exceptional events ...   [37]       In my opinion, the applicant’s situation fits precisely within all those considerations. ... The application is referred back to another authorized representative of the Minister of National Revenue for consideration in accordance with the reasons set out in this judgment.             ...

There was no consideration for it, and it was unearned. In essence, it was unique and extraordinary and bore all the earmarks of a windfall. ... The total amount received by the plaintiff in consideration for the expropriation of his interest in the Sparks Street property was $756,256.20. ... The payment was partial consideration for and in recognition of the plaintiff’s property interest. ...

Inadequate considerations. (1) Except as expressly otherwise provided in this Act, (a) where a taxpayer has acquired anything from a person with whom he was not dealing at arm's length at an amount in excess of the fair market value thereof at the time he so acquired it, he shall be deemed to have acquired it at that fair market value; (b) where a taxpayer has disposed of anything (i) to a person with whom he was not dealing at arm's length for no proceeds or for proceeds less than the fair market value thereof at the time he so disposed of it, or (ii) to any person by way of gift inter vivos, he shall be deemed to have received proceeds of disposition therefor equal to that fair market value; and (c) where a taxpayer has acquired property by way of gift, bequest or inheritance, he shall be deemed to have acquired the property at its fair market value at the time he so acquired it. (4) Where property of a corporation has been appropriated in any manner whatever to, or for the benefit of, a shareholder, for no consideration or for a consideration below the fair market value, if the sale thereof at the fair market value would have increased the corporation's income for a taxation year, for the purpose of determining the corporation’s income for the year, it shall be deemed to have sold the property during the year and to have received therefor the fair market value thereof. ... There was no consideration paid to the company. I therefore conclude that the appeal of Saskan Investments Ltd. must also fail. ...

Accordingly, as will be seen, the question compels a consideration of U.S. law in light of the Convention's definition of "resident" which is: Article IV Residence 1. ... The expression ” by reason of [the stated factors], or any other criterion of a similar nature”, indicates no narrow, rigid, unthinking or literally exclusive consideration. ... A literal or legalistic interpretation must be avoided when the basic object of the treaty might be defeated or frustrated in so far as the particular item under consideration is concerned. ...