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If the claim should be deemed worthy of consideration, the competent authority of such State may consult with the competent authority of the other State to determine whether the double taxation in question may be avoided in accordance with the terms of this Convention. ...

Those were some of the considerations. (SN p 70-71). 3.08 In cross-examination, Mr Grainger testified that: (a) his firm prepared the income tax returns of the four companies since 1971; (b) he recognized a document (Exhibit R-5) filed by his firm entitled “Agreement among Associated Corporation” (it is a T-2013 Form of the Department of National Revenue, Taxation); on this document, Ronda is considered as an associated company with the three others to allocate in 1972 the $35,000 subject to the lower rate, and the $50,000 business limit. 3.09 In the re-examination of Mr Grainger, an amended form T-2013 (and two pages) for the 1976 taxation year was filed as Exhibit A-6. ...

Commissioner Davis said at 320: After a careful review and thoughtful consideration of the evidence adduced and of the provisions of Section 85D of the Income Tax Act under which this appeal falls to be decided, I have reached the conclusion that the section taken as a whole, which, in my opinion, is the way in which it must be interpreted, is intended to apply to persons who fall to be taxed or otherwise dealt with under the provisions of the Canadian Income Tax Act and who report to the Canadian Government the income arising from the operation of the business or businesses whose sale is the central concern of the said Section 85D. ...

Paragraph 1 of Exhibit A-l reads as follows: This will confirm my purchase from you and your sale to me of 8,400 common shares of Cemp Holdings Ltd (hereinafter called “the Company”) without nominal or par value for and in consideration of a purchase price of $21.00 per share aggregating $176,400 whereof $100 has been paid on account as herewith acknowledged by you, and the balance shall be payable ten (10) years from date hereof. ...

These considerations thus led the MUC and the Fraternité des policiers to opt for a new formula, the one contained in the new article XX. ...

Hansen and Secora agree to give unto the Edwards an option (to be executed contemporaneously herewith) to purchase an undivided one-third interest in the said lands for a consideration of Thirteen Thousand Five Hundred Dollars ($13,500.00) of lawful money of Canada, such option to be exercised within six (6) months of the date hereof. ...

However, the problem arose for the Justices when they were required to give consideration to the phrase “taxpayer’s chief source of income”. ...

Ball It might appear at first glance that since the gain was realized on this piece of property in the same sale that dealt with Hooke, it should not have separate consideration from that of Hooke. ...

The prospect of self-incrimination under cross- examination, in a penalty assessment, should not be added to that burden without serious consideration. ...

However, the Income Tax Act has made an important and consistent legal distinction between income from a business and income from investment or property, and it seems to me that this basic distinction is an essential consideration in determining whether or not the appellant falls within the meaning of subsection 125(1) of the Income Tax Act. ...