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Results 91 - 100 of 636 for consideration
EC decision
Settler Oils Limited v. Minister of National Revenue, [1968] CTC 252, 68 DTC 5168
In my view, none of these cases have any application to the facts of this case which, as I understand them from this point of view, do not differ in principle from the facts under consideration in Balstone Farms Ltd. v. ... (supra) at page 41: ‘‘In none of these realization cases was there an out and out transfer by former owners for a cash consideration.’’ ... What the appellant did in this case was grant certain "‘leases’’ of its mineral rights that did not differ in character from the mineral lease under consideration in Berk- heiser v. ...
EC decision
Front & Simcoe, Limited v. Minister of National Revenue, [1960] CTC 123, 60 DTC 1081
However, before the time arrived when the Lessee could avail itself of its right to have the said sum applied on account of rent, the Lessee surrendered all its rights to the said sum, in consideration of the Appellant’s accepting the surrender of the Lease dated the 22nd day of August, 1949, and granting a new lease dated the 10th day of March, 1954. 12. ... In March, 1932, the Appellant Company granted to another company a licence to use the track from 1st May, 1932, to 29th April, 1941, in consideration of a percentage of the gross takings, with certain minimum weekly payments. ... Lawrence, J., distinguished both these cases from the one he had under consideration. ...
EC decision
Grand Marais Development Company Limited v. Minister of National Revenue, [1965] CTC 486, 65 DTC 5286
Prior to the relevant times, all of the 1,000 common shares were issued for a consideration of $1,000 and they remained issued and outstanding during all relevant times. ... During the trial I raised with counsel the question whether the three sales above mentioned might be subject to different considerations. ... Each of the three sales is accordingly subject to the same considerations and each forms, in effect, steps in one overall plan. ...
EC decision
Minister of National Revenue v. Alfred Manaster, [1958] CTC 244, 58 DTC 1144
On the other hand, the respondent submits that he received the said sum in pursuance to the terms of an agreement which establishes that the consideration for the payment was twofold. ... The agreements were cancelled and terminated following negotiations which led to the signing of an agreement whereby, in consideration of the termination of the agreements which existed between the parties, the respondent received a lump sum. ... Furthermore, the document states that the payment was made in consideration of the termination of the agreement and the assumption of the undertaking by the Schouella Bros. of Canada. ...
EC decision
In Re the Dominion Succession Duty Act, v. In the Matter of Margaret H. O’brien, [1957] CTC 266, 57 DTC 1201
The consideration expressed in the deed was "‘the giving back of a mortgage for $15,000, other good and valuable consideration and the sum of one dollar’’. ... While I think the alternative course of buying an unproved site and setting up a new station at lower cost might well be a consideration operating as a control on the amount that might be offered for a proven outlet, I do not think that the cost of new sites affords a satisfactory basis for comparison. ... These considerations lead me to conclude that Mr. Laffey’s estimate is too low. ...
EC decision
Minister of National Revenue v. Barbara A. Robertson, [1954] CTC 110, 54 DTC 1062
The Minister has determined that the respondent’s chief source of income was neither farming nor a combination of farming and some other source of income and an examination of his determination requires a consideration of the meaning of the words 4 ‘income” and ‘‘source’’ as used in the Act. ... In the case under consideration the only income which the respondent had was from her investments and the only source of that income was the securities in which that portion of her capital was invested. ... Consideration has been given to the cases cited on behalf of the respondent, viz.: Hatch v. ...
EC decision
His Majesty the King on the Information of the Attorney-General of Canada v. Toronto General Trusts Corporation,, [1942] CTC 65
By deed dated June 6, 1898, some of the then next of kin of a lunatic for valuable consideration conveyed by way of mortgage their expectancies in the estate of the luna- tie to an insurance society subject to redemption on payment to the society of £40,000. at any time after the death of the lunatic with compound interest thereon at the rate of 414 per cent. per annum with annual rests. The mortgage may be shortly stated in these terms—that in consideration of £20,000. paid to the mortgagors by the mortgagees, the mortgagors as beneficial owners conveyed their interests in the real and personal estate of the lunatic to the mortgagees, subject to redemption on payment by the mortgagors at any time after the death of the lunatic to the insurance society of the sum of £40,000., with compound interest on the same at the rate of 414 per cent. per annum from the day of the death of the lunatic, with yearly rests. In consideration therefore of an advance of £20,000. the mortgagors were to pay £40,000. on the death of the lunatic, and if that £40,000. was not then paid compound interest at the rate of 414 per cent with yearly rests was to be paid from that date. ...
EC decision
Pure. Spring Company Limited v. Minister of National Revenue, [1946] CTC 169
The considerations that may properly influence him depend upon the nature of the function he must perform. ... Up to three years an assessment is open to his unreserved consideration. ... Moreover, the assessment operation does not depend upon considerations ‘of. policy to be defined by the Minister. ...
EC decision
Holt Metal Sales of Manitoba Limited and Industrial Metals Processing Limited v. Minister of National Revenue, [1970] CTC 144, 70 DTC 6108
Nor is there any room for doubt that all the many income tax considerations were fully exposed and discussed by Mr. ... The onus of establishing that the sole, main reason was that of business consideration falls upon the appellants. ... An example of a case where other considerations dictated the creation of several corporations and the income tax benefit arising therefrom was only an incidental benefit, is Jordans Rug Ltd. et al. v. ...
EC decision
Allarco Developments Ltd. (Formerly Paris Investments Ltd.) v. Minister of National Revenue, [1970] CTC 390, 70 DTC 6274
In January 1965, the City of Edmonton acquired the 217.4 acres referred to in paragraph 8 hereof for a total consideration of $217,000.00 thus giving rise to a loss of $58,200. and has added a new paragraph 3A to its ‘ Reasons for Appeal ’ ’ in its Notice of Appeal, reading as follows: 3A. ... I think this would have been so if a trader in house properties took a house out of his inventories to use it for his private residence, and I see no difference where a trader removes trading inventories to use them as capital assets of a producing business or as consideration for the acquisition of such assets. ... I gave the appellant, during argument, an opportunity of electing for a further hearing but, after consideration, he decided not to accept it. ...