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From the latter case there is the statement: I do not say this consideration is absolutely final or determinative; but in a rough way I think it is not a bad criterion of what is capital expenditure to say that capital expenditure is a thing that is going to be spent once and for all, and income expenditure is a thing that is going to recur every year. ... I cannot see how these expenses can be considered in the same category as the expenses which were under consideration in the M P Drilling case. ...

(d) An equitable assignment of a future debt must be supported by valuable consideration. ... It is respectfully submitted that the transaction in question conforms to these particular tests, especially having regard to the intention to pass, as evidenced by the broker’s acknowledgement of the transaction; the specific identification of the bonds in question and the adequacy of the consideration tendered by the appellant as evidenced by the payment of $1,000 being the amount required to secure the bonds on margin. ...

In my view, when a debt is created from a company to a shareholder for no consideration or inadequate consideration, a benefit is conferred. ...

Background The basic facts are not in dispute and can be briefly summarized as follows: —The appellant is a Canadian corporation incorporated in Canada to carry on business; —The chief shareholder of the appellant is F Califano; — In 1970 the appellant acquired two parcels of real estate in the Township of Markham for a total consideration of $52,500; — Both of the said two parcels of real property were forcibly taken by the Department of Public Works of the Government of Canada on January 30, 1973; — By way of total compensation (exclusive of interest), the appellant received for the said forcible taking the sum of $96,512.69, which sum was received by the appellant in the following amounts on the following dates: Date Amount received 24 April, 1973 $27,321.89 10 October, 1973 15,108.00 12 October, 1973 19,262.00 28 July, 1974 22,614.00 10 May, 1975 12,206.80 — During ownership, the appellant had incurred certain carrying costs associated with the property. ... The Board has not been given a viable argument by counsel for the respondent which would allow for consideration of the payments at issue as other than “final”, and accordingly the argument of counsel for the appellant will be sustained. ...

I therefore think that the market price, in a case like that under consideration, where it is shown to have been consistent, determines the fair market value of the shares. ... It will be noted that Mignault, J said:... the market price must have some consistency and not be the effect of a transient boom or a sudden panic on the market. and again:... the market price, in a case like that under consideration, where it is shown to have been consistent, determines the fair market value of the shares. ...

It is not, however, a practical consideration. The receiver converts the signal received into a reconstructed version of the original signal transmitted by the broadcaster. ... Their Lordships are of opinion that the cardinal consideration in interpreting the Order in Council is the character and scope of the Order itself. ...

Attorney-General of British Columbia, [1978] CTC 462 Berger, J:—This case entails a consideration of the reach of provincial taxing power under the Succession Duty Act, RSBC 1960, c 372. ... He said: I now turn to consideration of the second point in issue which is whether or not paragraph 2(5)(b) of the Nova Scotia Succession Duties Act is ultra vires the province of Nova Scotia. ...

Ces deux moyens d’opposition, que les demanderesses présentent sur en même plan, n’ont pas la même portée et n’exigent pas la même considération. ... Seul le second moyen me paraît sérieux et digne de considération et c’est donc strictement en fonction du pouvoir de contrôle qui lui est dévolu en vertu du paragraphe 138A(3) ci-haut cité que la Cour doit analyser la contestation des appelantes. ...

The respondent states that, were one to stop one’s consideration of the “problem at this section, one could not say that the appellant was employed in Canada in 1973 and so the assessment as made could not stand. ... He submitted that there was no basis for an apportionment to enter into consideration of this matter. ...

Different considerations might prevail if there were more than two sources of income thereby resulting in different possible combinations. ... In seeking an answer, gross income, net income, capital investment, cash flow, personal involvement, and other factors may be relevant considerations. ...