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Finally, the Plaintiff also suggests that policy considerations support its interpretation of the Paragraph. ... Under the heading “Timber Limits and Cutting Rights” at page 35 the Notice reads in part: That where a taxpayer acquires after May 6, 1974, a property that is a timber limit or right or licence to cut timber from a timber limit or area in Canada, provided that all or any part of the cost may reasonably be regarded as consideration for an expectation of being able to or a right to renew, acquire or apply for a timber limit or a right or licence to cut timber from a timber limit or area in Canada... ...

The term flow-through shares is used to describe shares acquired by a taxpayer pursuant to an agreement with a corporation, whereby the corporation agrees to incur CEE and/or CDE in an amount equal to the consideration given by the taxpayer for the shares and to “renounce” the expenses in favour of the taxpayer. ... The consideration given by the Appellant for the flow-through shares was the payment of $32,312 paid on behalf of Norco for the renewal of coal licences, with the Province of British Columbia during each of the 1987 and 1988 taxation years. ...

P-1(118), in consideration of its extension to December 31, 1974, and of increased purchase commitments, Alcan agreed, inter alia, that Pillar International will receive from Alcan Aluminum a special credit of U.S. $120,000 in 1970. ... In computing income, no deduction shall be made in respect of an outlay or expense in respect of which any amount is otherwise deductible under this Act, except to the extent that the outlay or expense was reasonable in the circumstances. 69(1) Except as expressly otherwise provided in this Act, (a) where a taxpayer has acquired anything from a person with whom he was not dealing at arm's length at an amount in excess of the fair market value thereof at the time he so acquired it, he shall be deemed to have acquired it at that fair market value; (2) Where a taxpayer carrying on business in Canada has paid or agreed to pay, to a non-resident person with whom he was not dealing at arm's length as price, rental, royalty or other payment for or for the use or reproduction of any property, or as consideration for the carriage of goods or passengers or for other services, an amount greater than the amount (in this subsection referred to as "the reasonable amount") that would have been reasonable in the circumstances if the nonresident person and the taxpayer had been dealing at arm's length, the reasonable amount shall, for the purpose of computing the taxpayer's income from the business, be deemed to have been the amount that was paid or is payable therefor. ...

" Thus, a gift is a voluntary transfer of property owned by a donor to a donee, in return for which no benefit or consideration flows to the donor (see Heald, J. in The Queen v. ... Abemayor and reads as follows: KNOW ALL MEN BY THESE PRESENTS, that I, NELLY ABEMAYOR, residing at 40 Schenck Avenue, Great Neck, New York, DO HEREBY assign, transfer and set over all of my right, title and interest in and to certain Islamic Textiles listed in Schedule "A" annexed hereto, to ROYAL ONTARIO MUSEUM, 100 Queens Park, Toronto, Ontario, Canada M5S 2C6, for and in consideration of the sum of $67,500 U.S. dollars, by check subject to collection, receipt of which is hereby acknowledged, hereby warranting the title to said Islamic Textiles. ...

This practice, to which I have just referred, was, at least in part, dictated by cash flow considerations. ... The purpose of this tax credit is to pass on a tax benefit to eligible investors who acquire qualifying shares (generally the first registered holders of such securities) in a taxable Canadian corporation which has incurred expenditures on scientific research and experimental development if the issuing corporation has made a designation in a prescribed form filed with the Minister of National Revenue under subsection 194(4) (Part VIII of the Income Tax Act) in respect of the consideration for which it was issued. ...

It reads in part as follows:      That, where a taxpayer acquires after May 6, 1974, a property that is a timber limit or a right or licence to cut timber from a timber limit or area in Canada, provided that all or any part of the cost may reasonably be regarded as consideration for an expectation of being able to or a right to renew, acquire or apply for a timber limit or a right or licence to cut timber from a timber limit or area in Canada,... the proceeds of disposition [of such property]... shall be included in income.... ... The obvious intention was that, for tax purposes, any consideration paid for a right or expectation of a renewal, extension or substitution of a timber cutting right would be accounted for as part of the cost of the right, but any gain on the disposition of the right would be taxed as income. ...

(ii) a loss from the disposition of a debt or other right to receive an amount, unless the debt or right, as the case may be, was acquired by the taxpayer for the purpose of gaining or producing income from a business or property (other than exempt income) or as consideration for the disposition of capital property to a person with whom the taxpayer was dealing at arm’s length,   is nil;   SECTION 50: Debts established to be bad debts and shares of a bankrupt corporation   50. (1) For the purposes of this subdivision, where   (a) debt owing to a taxpayer at the end of a taxation year (other than a debt owing to the taxpayer in respect of the disposition of personal-use property) is established by the taxpayer to have become a bad debt in the year, or   (b) a share (other than a share received by a taxpayer as consideration in respect of the disposition of personal-use property) of the capital stock of a corporation is owned by the taxpayer at the end of a taxation year and:   (i) the corporation has during the year become a bankrupt (within the meaning of subsection 128(3)),   (ii) the corporation is a corporation referred to in section 6 of the Winding-up Act that is insolvent (within the meaning of that Act) and in respect of which a winding-up order under that Act has been made in the year, or   (iii) at the end of the year,   (A) the corporation is insolvent,   (B) neither the corporation nor a corporation controlled by it carries on business,   (C) the fair market value of the share is nil, and,   (D) it is reasonable to expect that the corporation will be dissolved or wound up and will not commence to carry on business,   and the taxpayer elects in the taxpayer’s return of income for the year to have this subsection apply in respect of the debt or the share, as the case may be, the taxpayer shall be deemed to have disposed of the debt or the share, as the case may be, at the end of the year for proceeds equal to nil and to have reacquired it immediately after the end of the year at a cost equal to nil ...

This is because a number of facts taken into consideration by accountants are excluded by certain provisions of the Income Tax Act in the determining of taxpayers’ profits. ... It is part of the consideration for an executed contract, the purchase of a used car. ...

I can find nothing in the context of the statutory provisions now under consideration which suggests that the words "manufacturing or processing of goods for sale” ought to be read in any way that extends their scope in ordinary usage. ... As previously noted similar considerations apply here. The change in temperature effected by the use of the microwave oven is so minor that it cannot be regarded as processing within the meaning of the provisions now in question. ...

It is not without significance that the consideration for the sale of the flavourings business was the book value thereof and was paid for by the assumption by Grover of Stuart’s liabilities in the approximate amount of $500,000 and the balance of $184,909 was payable, without interest, on demand. No part of the consideration was a payment for goodwill. By way of contrast, three years later, Givaudan Stuart Brothers Limited paid $750,000 for goodwill. ...