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He goes on to say, It is, of course, dangerous to rely on cases dealing with the interpretation of a particular section in a foreign taxation statute as so much depends on the exact wording of the section itself, on the accompanying interpretation sections of the particular statute, on the other interpretation statutes of general application in that jurisdiction as well on the particular context where the section under consideration is found. ...

Subsection 160(1) of the Act reads as follows: (1) Where a person has, on or after the 1st day of May, 1951, transferred property, either directly or indirectly, by means of a trust or by any other means whatever, to (a) his spouse or a person who has since become his spouse, (b) a person who was under 18 years of age, or (c) a person With whom he was not dealing at arm’s length, the following rules apply: (d) the transferee and transferor are jointly and severally liable to pay a part of the transferor’s tax under this Part for each taxation year equal to the amount by which the tax for the year is greater than it would have been if it were not for the operation of sections 74 to 75.1, in respect of any income from, or gain from the disposition of, the property so transferred or property substituted therefor, and (e) the transferee and transferor are jointly and severally liable to pay under this Act an amount equal to the lesser of (i) the amount, if any, by which the fair market value of the property at the time it was transferred exceeds the fair market value at that time of the consideration given for the property, and (ii) the aggregate of all amounts each of which is an amount that the transferor is liable to pay under this Act in or in respect of the taxation year in which the property was transferred or any preceding taxation year, but nothing in this subsection shall be deemed to limit the liability of the transferor under any other provision of this Act. ...

The Court now turns to a consideration of the terms, “such amount as is reasonable in the circumstances”. ...

The Appellant, most likely received these two Exhibits, not understanding the contents and left everything with the accountant for his perusal and consideration. ...

., concluded that the “considerable extra effort, attention, care and consideration by the teachers” given to the taxpayer’s legally blind son at an ordinary private school were insufficient to meet the provision’s requirement of ‘“personnel specially provided by that school, institution or other place’”. ...

It applies only in the context of section 231, which is concerned with the general subject of inspection, search and seizure in aid of enforcement of the Act, where far different considerations apply. ...

It appears to be conceded that the assessments cannot be sustained without the use of the unconstitutionally obtained evidence and that if the assessments were referred back to the Minister of National Revenue for reconsideration and reassessment on the basis that all evidence that was illegally obtained be excluded from the Minister’s consideration the Minister would have no evidence on which to base an assessment. ...

The burden should, therefore, be upon a claimant under the Charter to establish to the court’s satisfaction that the case is an appropriate one for the superior court’s immediate consideration. ...

These factors should then be analyzed to determine what weight they should be given in identifying the location of the property, in light of three considerations: (1) the purpose of the exemption under the Indian Act; (2) the type of property in question; and (3) the nature of the taxation of that property. ...

The accepted meaning of the term gift, for the purpose of the Income Tax Act, is a voluntary transfer of property without consideration: Burns v. ...