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The judgments are devoted in a great measure to a consideration of the prerogative under which the Crown was entitled to peculiar remedies against the debtor and his property, and of the law and the authorities bearing upon it. ...

Therefore, in view of the consideration to which I have just adverted I find that the preferred shares in question and the dividends paid thereunder are part of the subscribed capital and cannot in any manner or means be logically and legally considered as ‘‘borrowed capital”. ...

Therefore, in view of the consideration to which I have just adverted, I find that, in Canada, under the Income War Tax Act, 1917, the appellant, a co-operative company, is not exempt from the liability of paying income tax. ...

Marie [1921] 1 A.C. 288 at p. 290, where Duff J. said: ‘Their Lordships are not disposed to differ from the view pressed upon them that an agreement in order to receive effect under the statute must be very clearly made out; such an agreement, if effective, establishes a privilege in respect of taxation, and the principle is not only well settled, but rests upon obvious considerations, that those who advance a claim to special treatment in such matters must show that the privilege invoked has unquestionably been created.” ...

That question, as I have suggested, is one of law, to be answered by a consideration of the Act and the relevant decisions of the Courts. ... It will be observed that in that case consideration was given to the very question now before me, namely, whether the profit did arise in the actual year of payment, all trading transac- tions having been carried out in prior years. ... The consideration of how it would be prudent for a trader to act does not solve the question here presented to us as one of Revenue law. ...

I was not asked to give special consideration to individual assets, either on the law or facts, the contention of the appellant being that all of the assets were in fact the property of the husband. ... And all the surrounding circumstances of the case should be taken into consideration to determine whether a gift or a resulting trust was intended.” ... In my view, after a careful consideration of the evidence, the appellant has wholly failed to rebut the presumption that in placing assets in the name of his wife, Mr. ...

Basically similar considerations apply to the transactions in Roxboro shares as do to the transactions in Redwater shares. ... The Minister placed a valuation for $13,782.35 on that property which is the consideration for the 1,400,000 Roxboro shares. ... If Roxboro had issued its shares without nominal or par value for a cash consideration (as it must) which its directors considered to be the fair equivalent of the cash consideration of the property in excess of $13,782.35, then the difference would be income to the appellant, but the cost of the property, and accordingly the shares of the appellant, would remain the same. ...

Shown the notes exhibit 1 and asked if he had given consideration to their market value as of the date of Mrs. ... Kent added that this brought him back to the consideration of the balance sheet of Adam & Co. ... Why, then, after due consideration, it was my opinion and still is that if the notes of Adam & Co. ...

This leads to a consideration of whether, legally speaking, each of the holdbacks in the instant case possessed the quality required to bring it within the meaning of a receivable. ... This does not, however, dispose of the issue in regard to the contract under consideration. ... I will now pass on to a consideration of the relevant law applicable to the two Quebec contracts. ...

(a) Northern shall pay fees to Western at the rates specified in Appendix B (... or at the rates determined in accordance with Section 6(a) of Article I hereof) for the respective product groups, on each product subject to fee, as hereinafter defined, which is sold or leased (emphasis added) during the base period of this agreement, as also hereinafter defined, such rates to be applied to the net selling price of such product if sold for a separate consideration payable wholly in money and in all other cases to the fair market value thereof. ... Revenue Ruling 55-17: While manufacturing know-how is of a non-patentable nature it is something that its possessor can grant to another for a consideration. ... Convention, similar to the other two treaties, is drafted with the italicized addition in the undergoing style: The term “royalties” as used in this Article means any royalties, rentals or other amounts paid as consideration for the use of, or the right to use copyrights, patents, designs or models, plans, secret processes or formulae, trade-marks or other like property or rights, or for industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience (emphasis in text of citation). ...