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The rejection by the Department of a request for waiver of interest following a consideration of the matter by a fairness committee, and a review of the committee's decision by the Director of the District Office in conjunction with another, did not entail a breach of the Minister's duty to act fairly or to consider relevant evidence. ...

MNR, 2 DTC 918 (Ex Ct) in finding that although an agreement between the taxpayer and an American company indicated that payments were made solely in consideration for the right to use a line of clothing and the associated name, the taxpayer's evidence that the terms of the agreement also required the provision to the taxpayer of services, was admissible. ...

.)-- summary under Paragraph 251(1)(c) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) It was stated, in the context of the Bankruptcy Act, that a transaction is not at arm's length "where one of the co-contracting parties is, by reason of his influence, or superiority, in a position to pervert the ordinary rule of supply and demand and force the other to transact for a consideration which is substantially different than adequate normal or fair market value". ...

The Queen, 95 DTC 5187 (FCTD)-- summary under Subsection 220(3.1) Summary Under Tax Topics- Income Tax Act- Section 220- Subsection 220(3.1) Rouleau J. declined to set aside the decision of the Minister refusing to grant relief under s. 220(3.1) given the absence of bad faith on the part of the Minister, a breach of the principles of natural justice or consideration by the Minister of extraneous or irrelevant factors. ...

., [1998] BTC 438 (PC)-- summary under Exempt Receipts/Business Summary Under Tax Topics- Income Tax Act- Section 9- Exempt Receipts/Business Before going on to find that a lump sum received by an accounting firm in consideration for entering into a lease of office premises was a capital receipt, Lord Nolan stated (at p. 446) that: "The crucial question is whether in all the circumstances, the payment or receipt can properly be attributed to a particular year. ...

., [1998] BTC 438 (PC)-- summary under Expense Reimbursement Summary Under Tax Topics- Income Tax Act- Section 9- Expense Reimbursement Before going on to find that a lump sum received by an accounting firm in consideration for entering into a lease of office premises was a capital receipt, Lord Nolan stated (at p. 446) that: "The crucial question is whether in all the circumstances, the payment or receipt can properly be attributed to a particular year. ...

Furthermore, his conclusion that "a profit-oriented business person acting reasonably would not enter into the transactions, as described herein, in the absence of or excluding income tax considerations" violated the principle that "neither experts nor ordinary witnesses may give their opinions upon matters of legal or moral obligation, or general human nature, or the manner in which other persons would probably act or be influenced". ...

Accordingly, that activity of the City was engaged in for no consideration and, therefore, represented an exempt supply by virtue of s. 10 of Part VI of Schedule V. ...

Humphrey (1948), 30 TC 235 (HL)-- summary under Computation of Profit Summary Under Tax Topics- Income Tax Act- Section 9- Computation of Profit The taxpayer transferred mining concessions to a newly-incorporated company in consideration for shares of the company contemporaneously with an initial public offering of shares of the company. ...

The Queen, 75 DTC 5274, [1975] CTC 472 (FCTD)-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) In June 1967 a company ("Brilund") agreed to issue shares then worth no more than $120,000 to a non-resident shareholder, in consideration of past services rendered by him, but did not issue the shares to him until December, when the shares were worth substantially more. ...