Search - consideration
Results 111 - 120 of 636 for consideration
EC decision
Dominion Textile Co. Ltd. v. Minister of National Revenue, [1940-41] CTC 115
There is left, then, for consideration the third amount, approximately $759,822.79. ... Breadner in the end promised consideration would be given the same, and so these matters stood over for further considéra- tion. ... I have no doubt that if this matter were given favourable consideration by Mr. ...
EC decision
Moss v. MNR, 63 DTC 1359, [1963] CTC 535 (Ex Ct)
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 purpose 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 (i) as consideration or partial consideration for accepting the office or entering into the contract of employment, (ii) as remuneration or partial remuneration for services as an officer or under the contract of employment, or (iii) in consideration or partial consideration for covenant with reference to what the officer or employee is, or is not, to do before or after the termination of the employment.” ... This right was as much part of the consideration for accepting the office of sales manager and entering into the contract of employment and as much remuneration for his services as an officer or under the contract of employment as any of the payments specified in paragraph 1 of the agreement. ... It can, therefore, be reasonably regarded as having been received by the appellant as partial consideration for his acceptance of the office of sales manager of Prairie Cereals Limited and entering into the contract of employment of March 28, 1955, or as partial remuneration for his services as an officer of Prairie Cereals Limited or under his contract of employment. ...
EC decision
Meteor Homes Ltd. v. MNR, 61 DTC 1001, [1960] CTC 419 (Ex. Ct.)
The item of $32,500 in another connection has already been the subject of consideration by Fournier, J., in M.N.R. v. ... In paragraph 4 of the receipt, release and discharge (A-5) reference to an additional consideration of $32,500 is made in the following terms: ‘‘In consideration of the termination of the Agreement between the parties and of the assumption by the Second Parties of the undertaking, the Second Parties agree to pay to the First Parties the sum of $32,500 which the First Parties acknowledge to have received to their satisfaction at the execution hereof and whereof quit.” ... In my opinion, any evidence to the contrary notwithstanding, the main consideration for which the Schouelas undertook to pay the sum of $32,500 was to break a deadlock of their own creation and to obtain absolute control not only of the appellant company but also of Meteor-Century Builders Inc. ...
EC decision
The Algoma Central and Hudson Bay Railway Company v. Minister of National Revenue, [1961] CTC 9, 61 DTC 1027
They were in the basic form of a lease of land which, in consideration of rents and other considerations reserved, demises to the lessee a specified area for a specified period of time. ... It is evident that the Province was induced to part with the lands for the consideration that two large companies agreed to undertake works and developments which in the last analysis would be in the interest of both companies and the Province. ... Every covenant, agreement, was for a consideration which a unit price per acre on a designated area and for a specified period. ...
EC decision
Seaboard Advertising Co. Ltd. v. MNR, 65 DTC 5188, [1965] CTC 310 (Ex. Ct.)
For a consideration of $47,973.50 the appellant acquired an existing cafe business together with an assignment of the lease, to which a value of $32,000 was attributed. ... The question as to whether this amount of $32,000 can ‘‘reasonably be regarded as being the consideration for such disposition’’ can be determined by the evidence which, on this matter, in my view, indicates that the amount of $32,000 is in fact something less than the true value of this leasehold at the time the transaction took place if consideration is given to the fact that when one of Mr. ... In view of the above, it therefore follows that the amount of $32,000 does not appear to me to be an unreasonable consideration for the disposition of the leasehold interest herein. ...
EC decision
Jack Stupp v. Minister of National Revenue, [1968] CTC 361, 68 DTC 5235
On April 15, 1962, the appellant caused to have issued to him as fully paid and non-assessable 3,600 preference shares of a par value of $10 of Consumers Distributing (Adelaide) Limited and purported to give, according to the evidence, as consideration therefor, a $36,000 promissory note without interest. ...
EC decision
Avril Holdings Ltd. v. Minister of National Revenue, [1969] CTC 397, 69 DTC 5263
A memorandum signed by officers of the companies on March 2, 1962 acknowledged and confirmed that the said book value and consideration payable was $194, 716. 91. ... As partial consideration, the purchaser assumed liabilities of the vendor of $732,462.00. ... It is not so much the nature of the property which is taken into consideration but the fact that the property is giving rise to capital cost allowance. ...
EC decision
Nicholson Limited v. Minister of National Revenue, [1945] CTC 263
This requires consideration of the various items involved in the assessment and whether they have been properly included. ... He allowed the appeal and referred the matter back to the Minister for further consideration of reasonable allowance within the Act. ... The matters referred to by counsel are among the very considerations that Parliament has left to the discretion of the Minister. ...
EC decision
Harry Graves Curlett v. Minister of National Revenue, [1961] CTC 338
Section 3 of the Statement of Fact mentions 1948 as the year of incorporation under the Companies Act of Alberta, adding that this company ‘‘since incorporation has been engaged in the sale of investment contracts by which the Company, in consideration of periodic payments by contract holders, agrees to pay the holders a stated sum in one or more periodic payments...”. ... Curlett during the six material years, 1949 to 1954, out of his own personal funds, would advance to a client the amount agreed upon, at an 8% rate of interest and, above all, in consideration of a 15% discount. ...
EC decision
Freeholders Oil Company Limited v. Minister of National Revenue, [1966] CTC 301, 66 DTC 5235
The consideration paid by Freeholders for such a lease consisted of the allotment to the lesssor of one fully-paid share in its capital stock for each acre of land involved. ... The consideration from Freeholders for such an assignment consisted of a covenant for the allotment of one fully-paid share in its capital stock for each acre of land involved, of which one-half of the shares would be allotted forthwith and the other half only when the mineral lease to Freeholders should take effect. ...