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(UBS) entered into an agreement whereby Canaccord was to act exclusively as agent for UBS in connection with a proposed treasury financing for UBS for a minimum of $3,000,000 and a maximum of $6,000,000 raised (the "Offering) by way of a private placement of equity;   d)         in connection with the offering Canaccord agreed to: (1) use best efforts to structure, market and obtain commitments on mutually agreeable terms in respect of the proposed financing of the company; (2) comply with all applicable securities laws in respect of its obligations hereunder (3) advise the company as to the appropriate structure of the financing and assist with the preparation of required documentation; (4) organize meetings between representatives of the company and potential investors; and (5) assist the company in the negotiating and structuring of the final terms of the financing and assist with closing the transaction;   e)         part of the compensation Canaccord received for its services was a Compensation Option to purchase an aggregate of 10% of the Offered Securities issued or issuable at the issue price of the Offering for a period of 24 months;   f)          Canaccord allocated 742,692 UBS Compensation Options, or share purchase warrants (the UBS Warrants), or other consideration received in lieu thereof, to the Appellant on May 28, 1998;   g)         (i) on September 4, 1998 Unique Broadband Systems Inc. ... Further, in the event of the share warrants not being issued, UBS was required to compensate Canaccord in "other consideration in lieu thereof"; in such circumstances, Canaccord was likewise bound to pay a pro rata share of that alternate consideration to the Appellant- a promise worth very little if no quantifiable value could be ascribed to the share warrants unless or until they were issued, exercised and the shares sold. ... For example, when a corporation, for no consideration, grants on only some of its common shareholders, rights to purchase any additional shares of the corporation's capital stock, subsection 15(1) applies to those shareholders. ...

The payment also included a $10,000,000 contingent consideration based on future performance. ... The approach addresses the rationale of the PUC scheme specifically in relation to amalgamation and redemption and not a general policy unrelated to the scheme under consideration. ... This cash at closing portion of the purchase consideration implies an equity purchase price of $220 million with additional earn-out consideration and equity participation as detailed below. ...

The services are rendered under a single contract, for a single consideration, albeit the invoice is itemized. The appellant is making a single supply of livestock and the commission and disbursements charged are part and parcel of the consideration for that supply. ... The provision and delivery of the electricity is rendered under a single contract, and for a single consideration, albeit the invoice is itemized. ...

Cassell would reasonably be regarded as an officer or employee of WPNL but for the existence of ICL — required consideration of the decisions in Wiebe Door Services and Sagaz Industries (at paragraph 50): This case requires consideration of Wiebe Door Services Ltd. v. ... I believe, however, that it is a simple matter to adapt this test to the language of the PSB definition by asking whether, taking into consideration all the circumstances, Mr. ... Cassell would reasonably be considered to be an employee of WPNL. … 46   In light of all of these considerations, I have concluded that Mr. ...

This giving in payment is made in consideration for the full and final release by the creditor of the debtor for all sums owed to it in principal, interest, costs and incidentals, under the following deeds:... AMOUNT OF CONSIDERATION: $250,000 [17] Exhibit A-6 is the bid for repair work. ...

Pleadings   General considerations   [14]          It will be useful to consider further some of the rules that apply to pleadings ... I would not want what I have said above to be taken as necessarily governing the rules of pleading in informal cases, where there are no discoveries, and other considerations may apply. [6] The “assumptions” have been referred to in a variety of ways. ...      [25] There is another consideration. In the informal procedure, there is no documentary discovery or oral examination for discovery. ...

Cattanach J. stated the following at page 323:               It is not a question of the Minister or this Court substituting its judgment for what is a reasonable amount to pay, but rather a case of the Minister or the Court coming to the conclusion that no reasonable business man would have contracted to pay such an amount having only the business consideration of the appellant in mind. I do not think that in making the arrangement he did with his brother Robert that Jules would be restricted to the consideration of the service of Robert to the appellant in his first three months of employment being strictly commensurate with the pay he would receive. I do think that Jules was entitled to have other considerations present in his mind at the time of Robert's engagement such as future benefits to the appellant which he obviously did. ...

.- That a good share of "CCI's" profits were transferred to "Atuhk". [25]     When asked whether tax considerations led them to set up Atuhk on the Mashteuiatsh reserve, Danny Cleary did not provide a direct answer to the question. ... These factors should then be analyzed to determine what weight they should be given in identifying the location of the property, in light of three considerations: (1) the purpose of the exemption under the Indian Act; (2) the type of property in question; and (3) the nature of the taxation of that property. ... In any case, whether the project in Mashteuiatsh is a product of humanitarian considerations, as submitted by Ralph and Danny Cleary, or a product of financial-planning opportunism, the reality is this: Atuhk's profits are essentially profits related to the construction company, CCI, which is run on the South Shore of Montréal. ...

The donor must be aware that he will not receive any compensation other that pure moral benefit; he must be willing to grow poorer for the benefit of the donee without receiving any such compensation. [41] [Italics are in the original.] [51]   In discussing the concept of donative intent in Webb, Justice Bowie stated: These cases [Friedberg and others] make it clear that in order for an amount to be a gift to charity, the amount must be paid without benefit or consideration flowing back to the donor, either directly or indirectly, or anticipation of that. ... In 897366 Ontario Ltd., Associate Chief Justice Bowman (as he then was) stated: The imposition of penalties … requires a serious and deliberate consideration by the taxing authority of the taxpayer’s conduct to determine whether it demonstrates a degree of wilfulness or gross negligence justifying the penalty…. ... In Backman v The Queen, [2001] 1 S.C.R. 367, 2001 SCC 10, ¶22, the Supreme Court of Canada stated, “This court has repeatedly held that a tax motivation does not derogate from the validity of transactions for tax purposes…;” and in Cassan et al. v The Queen, 2017 TCC 174, ¶260, the Tax Court of Canada stated, “the fact that a taxpayer is motivated by tax considerations does not in and of itself vitiate the result under the applicable private law.” [38]   Berg, supra note 37, ¶23. [39]   Friedberg, supra note 37, ¶4. [40]   Coombs et al. v The Queen, 2008 TCC 289, ¶15. [41]   The Queen v Burns, [1988] 1 CTC 201, 88 DTC 6101, ¶28 (FCTD). ...

The Minister cannot deliberately ignore its juridical act and use the BIA to bypass all the other legislation without consideration for federal or provincial legislation governing the relationship between creditors and debtors;     III. ... This juridical fact in itself represents the consideration. The Minister cannot rely on another juridical act or "another law" to impose tax liabilities on the Company's former administrators;                          47.                ...