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There remained consideration for remission of taxes under the Financial Administration Act. ... Consideration of requests of this nature involves an extensive and fully objective review of the facts of the particular situation and a careful evaluation of the merits of the request to ensure fair and uniform application of established criteria. ... I can assure you that he will receive the utmost consideration possible in the resolution of his case. ...

Consideration of requests of this nature involve an extensive and fully objective review of the facts of the particular situation by senior departmental officials in Head Office.  ... I wish to assure you that the pensioners will receive the utmost consideration possible in the resolution of their cases. ...

You have also asked that consideration be given to taxing strike pay, to the extent that such pay exceeds dues paid by the worker. ... As such amendments are the responsibility of the Honourable Paul Martin, Minister of Finance, it was appropriate that you sent him a copy of your correspondence for consideration. I trust that the Department of Finance will give your recommendations due consideration. ...

Subsection 206(4) of the Act provides that where an RRSP, RRIF or other taxpayer acquires a property from a person with whom the taxpayer was not dealing at arm’s length, for no consideration or for consideration that is less than the fair market value of the property at the time, the taxpayer will be deemed to have acquired the property at its fair market value. ...

Jones is distinguishable from the case under consideration for a number of reasons.  ... Jones the guarantee was given for no consideration except for an agreement to purchase tobacco products from the guarantor and could therefore produce no income in and by itself.  ...

Coincident with completion of the Take-Over Bid, there is a transfer of assets by Target to a wholly-owned subsidiary, with an election under subsection 85(1) to defer the gain on the assets transferred, and share consideration is taken back.  ... (b)     Disposition of Property      Question      A Parent transfers assets to its wholly-owned subsidiary in exchange for share consideration, electing under subsection 85(1).  ...

Consideration of this matter is not yet complete, however.  As indicated during the Round Table discussion, the Department currently considers that the income tax treatment of original-issue discount is ultimately a question of fact.  ... The comments in this letter are of general nature only and do not take into account considerations that might arise in connection with a specific transaction or event.  ...

Pratte, J. stated at page 6083 that "I must now consider the respondent's submission that the expenditure, assuming it to have been an outlay on account of capital, had been made to acquire a franchise with the result that the respondent could, in the computation of its income for the years under consideration, deduct a capital cost allowance under section 11(1)(a) of the Income Tax Act and section 1100(1)(c) of the Regulations.  ... Goodwin Johnson (1960) Ltd., 86 DTC 6185  (F.C.A.), Pratte J. stated at page 6191 that, in deciding whether a payment received by a taxpayer constituted an eligible capital expenditure, it was necessary to determine (1) what consideration was given by the taxpayer for the payment, and (2) whether, if the taxpayer had made a payment for that consideration, that notional payment would have been an eligible capital expenditure in respect of the taxpayer's business.  ... Pratte J. concluded that the consideration that the taxpayer gave for receipt of the settlement payment was its rights under the contract and that if Goodwin had paid an amount to acquire those rights, that payment would have been on capital account and hence an eligible capital expenditure. ...

All situations are of interest and your submission will be given consideration. ...

Je vous prie d'agréer, Madame, l'assurance de ma considération distinguée. ...