Search - consideration

Results 61 - 70 of 636 for consideration
EC decision

New St. James Limited v. Minister of National Revenue, [1966] CTC 305, 66 DTC 5241

Olympic Properties Limited gave no consideration for the rebate, hence it is a gift. ... That entry could imply an intention to pay that sum or even a promise to pay, but it is without consideration and being without consideration the promise has no binding effect: Eastman v. ...
EC decision

Donald Preston McLaws v. Minister of National Revenue, [1970] CTC 420, 70 DTC 6289

By an agreement dated January 2, 1952 he purchased the assets of the old company for a consideration which included payment of $225,000 and assumption of debts. ... One consideration may point so clearly that it dominates other and vaguer indications in the contrary direction. ... Nor was any consideration given to charging interest to the subsidiary on advances made by the respondent. ...
EC decision

Alex Miller v. Minister of National Revenue, [1962] CTC 199

The consideration for this assignment was $12,000 to be paid at once and 42 per cent of the moneys received pursuant to it by A.M.I. ... Inland Revenue (21 Tax Cas. 608), Lord Normand (Lord President), said (ibid., at p. 619): ‘... no infallible criterion emerges from a consideration of the case law. ... On that sort of consideration this case might well have been different if the £4,000 had been paid because the taxpayer’s goodwill had been damaged. ...
EC decision

Helmut William Bruno Schroder and Charles Geoffrey Vickers, Executors of the Will of Emma Christine Maria Theodore Schroder, Deceased v. Minister of National Revenue, [1955] CTC 290, 55 DTC 1128, [1955] CTC 289

Marga also sold like amounts of debentures and stocks to Maculata Limited for the same consideration, except that the option to re-purchase was in favour of Dorothea. Likewise, Helmut sold to Mithra Limited like amounts of debentures and stocks for the same consideration except that the option to re-purchase was in favour of Marga. ... It will be noted, also, that I have given consideration to the origin and history of Winley Limited from its inception. ...
EC decision

Williams Brothers Canada Ltd. v. MNR, 62 DTC 1276, [1962] CTC 448 (Ex Ct)

The consideration for the assignment and the sale of certain equipment was $325,000. ... Attached to the letter was an agreement respecting the sale of equipment which was for a consideration of $95,000. By subtraction, therefore, the consideration for the assignment of the interest of Canadian Pipe Line Construction Co. ...
EC decision

David J. Foster v. Minister of National Revenue, [1971] CTC 335, 71 DTC 5207

In each of them, (a) the appellant acquired a number of mining claims; (b) the appellant sold the mining claims to a company that he had caused to be incorporated for a consideration consisting of shares in that company; (c) the appellant sold the shares that he had received (or most of them) to a company or companies the shares of which belonged to him or to members of his family; (d) the appellant, in the course of a business as a “brokerdealer” that he operated under the name of Durham Securities, carried on, on behalf of the company or companies to which he had sold the shares, a campaign to sell those shares to the public. ... The respondent denies that the facts fall within Section 83(3) and says that, even if they do, Section 83(3) does not apply by virtue of Section 83(4), which reads as follows: (4) Paragraph (b) of subsection (2) and paragraph (b) of subsection (3) do not apply: (a) in the case of a person who disposes of the shares while or after carrying on a campaign to sell shares of the corporation to the public, or (b) to shares acquired by the exercise of an option to purchase shares received as consideration for property described in paragraph (a) of subsection (2) or paragraph (a) of subsection (3). ... I have given full consideration to the doubt raised by this feature of the evidence before finally reaching the finding of fact expressed in this paragraph. ...
EC decision

Marflo Drilling Company Limited (Formerly Marflo Oils Limited) v. Minister of National Revenue, [1967] CTC 281, 67 DTC 5196

Accordingly, at the same time, it was provided that, where petroleum or natural gas rights are sold, “any amount received... as consideration for the disposition” is to be included in computing income (Section 83A(5b)). ... The obligation of bringing into income amounts received as consideration for the disposition of petroleum or natural gas rights was imposed in respect of dispositions after April 10, 1962, unless (inter alia) such right was both (a) acquired on or before that date, and (b) disposed of before November 9, 1962. ... Had the matter been one where Parliament had simply required that an amount of a capital nature be included in computing income, I should have felt constrained to give the submission, which was put forward very persuasively indeed, very careful consideration. ...
EC decision

Minister of National Revenue v. William Albert Hansen, [1967] CTC 440, 67 DTC 5293

CONSIDERATION. The consideration for this Agreement is the mutual promises and agreements herein contained. 2. ... Some such considerations may be helpful in certain cases in deciding whether particular payments are to be made for the wife’s maintenance or not. ... With reference to the contention that the payments were really part of the consideration running from the appellant under the agreement for all the various benefits accruing to him under the agreement, I have already made it clear that, as I read the agreement, it has been so constructed so as to make paragraph 7 a provision for maintenance and nothing else. ...
EC decision

Luscar Coals Limited v. Minister of National Revenue, [1949] CTC 26

To ascertain whether there have been “losses” necessarily involves consideration of both sides of the balance sheet. ... Judicial consideration has been given to the meaning of section 6(1)(a) of the Act which then was as follows: " " 6. ... I have given careful consideration to the other cases which were cited but have reached the conclusion that they are not here helpful. ...
EC decision

Calona Wines Ltd. v. Deputy Minister of National Revenue for Customs and Excise, [1969] CTC 235, 69 DTC 5190

I may have a good “bargaining position’’ when bargaining for a sale or other contract, but I do not sell or otherwise use this “bargaining position’’ as consideration. I use the “bargaining position’’ as a means of persuading the other party to give me more than he otherwise would for the property or other consideration that I have to dispose of. ... When it agreed to continue to accept the lower price for the more expensive power in consideration of being provided with the capital additions and improvements, it was, in effect, getting the additions and improvements in consideration of surrendering its right to deliver 25 cycle power and agreeing to provide 60 cycle power at a price lower than would otherwise have been economic. ...

Pages