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In my view, that is a relevant consideration. That is not to suggest that the taxpayer’s current circumstances are irrelevant. But it is to say, that all of his circumstances are relevant to the matter under consideration. [15] Mr. ... [emphasis added] [18] The proportion of interest accrued to the underlying tax debt is not a stand alone consideration. [19] Unlike Mr. ...

The following provisions of the Income Tax Act are in play: 5. (1)... a taxpayer’s income for a taxation year from an office or employment is the salary, wages and other remuneration, including gratuities, received by him in the year. 6. (3) An amount received by one person from another (a) during a period while the payee was an officer of, or in the employment of, the payer, or (b) On account or in lieu of payment of, or in satisfaction of, an obligation arising out of an agreement made by the payer with the payee immediately prior to, during or immediately after a period that the payee was an officer of, or in the employment of, the payer, shall be deemed, for the purposes of section 5, to be remuneration for the payee’s services rendered as an officer or during the period of employment, unless it is established that, irrespective of when the agreement, if any, under which the amount was received was made or the form or legal effect thereof, it cannot reasonably be regarded as having been received (c) as consideration or partial consideration for accepting the office or entering into the contract of employment, (d) as remuneration or partial remuneration for services as an officer or under the contract of employment, or (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. 56. (1) Without restricting the generality of section 3, there shall be included in computing the income of a taxpayer for a taxation year, (a) any amount received in the year as, on account of or in lieu of payment of, or in satisfaction of, (ii) a retiring allowance, (viii) a termination payment; 248. (1) In this Act “retiring allowance” means an amount received upon or after retirement from an office or employment in recognition of long service or in respect of loss of office or employment (other than a superannuation or pension benefit), whether the recipient is the officer of employee or a dependant, relation or legal representative; “termination payment” for a taxation year means an amount equal to the lesser of (a) the aggregate of all amounts each of which is an amount received in the year in respect of a termination of an office or employment, whether or not received pursuant to an order or judgment of a competent tribunal, other than (i) an amount required by any provision of this Act (other than subparagraph 56(1)(a)(viii)) to be included in computing the income of a taxpayer for a year, (b) the amount by which 50% of the aggregate of all amounts each of which is the amount that may reasonably be considered to be the employee’s salary, wages and other remuneration from an office or employment for the 12 months preceding the date that is the earlier of (i) the date on which the office or employment was terminated, and (ii) the date on which an agreement, if any, in respect of the termination was entered into exceeds the amount determined under paragraph (a) for each previous year in respect of that termination whether the recipient is the officer or employee whose office or employment was terminated or a dependant, relation or legal representative of the officer or employee; I do not accept the plaintiff’s thesis that this was, in fact, a $25,000 lump sum settlement of a right of action for dismissal without reasonable notice. ... While it was an amount within paragraph (a), it cannot reasonably be regarded as having been received as consideration for any of the things enumerated in paragraphs (c), (d) or (e) thereof. ...

Sans cette considération le défendeur n'aurait pas rendu le service d’endosser le billet de $63,000. ... Le fait d’endosser, de prendre un risque, constitue à mon avis une activité, même s’il n’y a aucune considération attachée au service. S'il y a considération attachée à l’endossement, à mon avis, le benefice qui en découle est celui d’une entreprise tel que cette expression est décrite à l’article 139(1)e). ...

Where the discretion has been exercised in good faith, in accordance with the principles of natural justice, taking into account all relevant considerations and without reliance placed upon irrelevant ones, the Court should not interfere. 3 [10]      In the case at bar, there is no evidence that the Minister"s delegate improperly exercised his discretion. [11]      First, the decision of the Chief of Appeals is rational and based on relevant considerations. When assessing the particular circumstances of this case, the Chief of Appeals took into account the considerations outlined in paragraph 10 of its own guidelines. ... It is simply reflective of the fact that when the Minister exercises his discretion under subsection 220(3.1), he is required to take into account considerations relevant and unique to that taxpayer alone. ...

Positions of the Parties [7]                In the context of this judicial review, the applicant argues that the officer erred by not taking into consideration all the evidence on file. ... Khosa, [2009] 1 S.C.R. 339, 2009 SCC 12, at paragraph 61), the only issue in the present case is to determine if the officer’s decision not to take into account humanitarian and compassionate considerations is reasonable. [10]            For the reasons that follow, the application for judicial review is dismissed. [11]            The Court agrees with the respondent that the officer was not required to consider the applicant’s rehabilitation, given that no such application had been filed. ... Canada (Citizenship and Immigration), 2015 FC 1310). [12]            As for humanitarian and compassionate considerations, the officer was not required to take them into account because this is not an application based on humanitarian and compassionate considerations under subsection 25(1) of the IRPA (Pizarro Gutierrez v. ...

Ipaye’s counsel raised fairness arguments relating to the RAD’s failure to grant an oral hearing, its consideration of a jurisprudential guide relating to IFAs in Nigeria, its consideration of documentation contained in the then-current National Documentation Package, and its assessment of certain evidence. [10]   None of these issues were raised in the written submissions seeking leave that were filed on Ms. ... No objection was made to the RAD’s consideration of an IFA and no written submissions were filed. [18]   The RAD did not err in dismissing the appeal on the ground that Ms. ... Ipaye or her counsel. [21]   The RAD engaged in detailed consideration of both the possibility of persecution and the reasonableness of the proposed IFAs. ...

His decision was based on relevant considerations and made in a rational manner with regard to all the facts before him. ... First, the decision of the Chief of Appeals is rational and based on relevant considerations. When assessing the particular circumstances of this case, the Chief of Appeals took into account the considerations outlined in paragraph 10 of its own guidelines. ...

Under these provisions, consideration may be given to waiving interest in those instances where an individual is experiencing financial hardship, and has no ability to pay the liability in full. ... Barrons, and reviewing the material, I am completely satisfied that the decision was made fairly, on reasonable advice to her, and also on reasonable consideration. ... A great deal of time and attention was paid to her submissions, and a great deal of time and consideration was given to the result. ...

In fact it never received either the repayment of the advance or the minimum consideration of $42,000 owing to it in respect of the advance. ... Once again it is necessary to fit a transaction shaped by transitory business considerations on to the Procrustean bed of the Income Tax Act, R.S.C. 1952, c. 148 (am. ... The agreement also in paragraph 8 refers to the "repayment" of the guaranteed return of $42,000 owing as consideration for the making of the advance. ...

No valuable consideration was given to the husband as payment for this transfer at the time when he had an unpaid tax liability to the Minister of National Revenue ... A discretionary power of this nature must be exercised in good faith, in accordance with the principles of natural justice, taking into account all relevant considerations and without regard to irrelevant or extraneous ones. ... [W]hen the Minister exercises his discretion under subsection 220(3.1), he is required to take into account considerations relevant and unique to that taxpayer alone ...