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Analysis (a) General Civil Litigation Considerations [8] There are two aspects to these motions. [9] The first relates to the question: when in civil litigation is it appropriate to allow an amendment? ... (b) Tax Litigation Considerations [14] This second aspect is this: are there specific tax litigation considerations limiting how the Respondent may defend an appeal? ... Subject to the general civil litigation considerations, they may raise new arguments and new issues not raised previously. [23] The exception is with respect to “large corporations” as defined in the Income Tax Act. [6] [24] With respect to the Respondent, limitations on what arguments and issues may be raised emerged from a number of court decisions. ...

Hussain and that GEM properly calculated and charged the appropriate amount of consideration for those management services. As well, I find that GEM collected and remitted the appropriate amount of GST/HST in respect of that consideration. ... Hussain, with the result that GEM properly calculated and charged the appropriate amount of consideration for those services and collected and remitted the correct amount of GST/HST in respect of those services ...

Consideration for Services or Provincial Grant Without Consideration? ... That is, do the parties intend the purchase of a supply for consideration? ... Hence, no consideration was paid to the City by the Government of Saskatchewan. ...

If there is consideration, it’s not – there’s no reason to restrict the consideration to payment for business assets. ... Consideration:   30. One of the four requirements for application of subsection 160(1) is that there must be no consideration or inadequate consideration flowing from the transferee to the transferor. ... She gave consideration in return for the subject funds, being her commitment to Dr. ...

For the purposes of calculating the transferee's liability, the fair market value of the consideration given, if there is a consideration, is taken into account for the property transferred by the transferor. ... In other words, domestic obligations cannot be consideration within the meaning of section 160. ... But what was that consideration? Can it be said that the paying of household expenses is consideration for the transfers? ...

whether the grant funding is consideration for that supply, are determined as follows: 1.        ... As such, there is a direct link between the supply and the consideration. ... That legislation, in this case, includes a definition of "consideration". ...

Thus, the cost of the partnership interest is the value of the transferred asset for which the partnership interest, or increased partnership interest, was received as consideration. ... The aggregate consideration received by the Appellant was similarly described as approximately $8M by way of promissory notes and units in the Partnership. ... It would seem to follow that consideration of legislative purpose may not only resolve patent ambiguity, but may, on occasion, reveal ambiguity in apparently plain language.” ...

Greenspoon confirmed that “ the transaction by which Lord Black advanced US$15,315,364.74 ” had not been documented and he continued as follows: It has always been recognized that any determination of what, if anything, Lord Black is to receive in consideration of the advance of such sum to International would involve a careful analysis of the following considerations, among others: (i) the restrictions under the Wachovia Indenture on the ability of Inc. and certain of its subsidiaries to incur indebtedness or grant security; (ii) whether or not any advance to Inc. or any of its subsidiaries would come from Lord Black or an entity controlled by Lord Black (e.g. ... Greenspoon’s correspondence, there was no agreement as to what, if anything, Lord Black or an entity to be controlled by him would receive in consideration of the funds advanced toward payment of the judgment. [63]   Mr. ... (c) Exchange of Legal Consideration [130]   Black and Inc. exchanged valuable consideration. ...

Implementation of the Well Classification System- Policies and Procedures 2.1 Technical Considerations (a) When classifying a well, the Board takes into account such considerations as the geological objectives and projected total depth of the well, the geological conditions and known existence of hydrocarbons in the area in which the well is to be drilled, and, in its judgement, the general degree of the risk of failure involved. ... (f) When it initially classifies a well, the Board does not take into account the impact of the classification on the Exploratory Drilling Assistance Program or any other regulatory consideration. ... Counsel for Respondent stated one must be governed by objective considerations rather than subjective estimates of risk. ...

Counsel for the respondent also relied on a resolution of the board of directors of New Asia Investment Corporation Inc. granting Do Hee Lim a certificate for 12 preferred shares in consideration of a sum of $200,000 plus other consideration. ... THAT, in consideration of a sum of 200 000 $ plus other consideration transferred to the corporation, a certificate of twelve (12) Preferred Series II shares be issued to and in favour of Mrs. ... The company may issue fully-paid shares only for a consideration of actual and present property or actual past services. ...