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Axelrod v. The King, 2022 TCC 157 (Informal Procedure)

Justice Campbell concluded that Hurd PC made a single supply of orthodontic treatment to each patient for a single consideration or fee. ... Therefore, the question to be addressed is what was supplied by Aeroplan to CIBC for the consideration paid by CIBC?... ... Axelrod to his patients for the consideration (i.e., the fees) that they paid to him, or, in other words, what was the reason for the payment of those fees? ...

Global Communications Ltd. v. R., [1997] 3 C.T.C. 2499, 97 D.T.C. 1293

Each knew that the other did not provide the consideration which it purported to transfer. The expression for this used by one text book is that the consideration was “illusory”. ... Neither party to the alleged transaction of August 29, 1991 presented a representative to testify as to the consideration or knowledge of the consideration allegedly passing between the parties on August 29, 1991. ...

Consolidated Denison Mines Limited and the Rio Tinto Mining Company of Canada Limited Et Al. v. Deputy Minister of National Revenue for Customs and Excise, [1963] CTC 290

In cross-examination when asked as to whether one of the primary things for a person in charge of a mine to do was to conduct the operations in such a way that as little rock as possible is mixed with the ore (this is called dilution) he stated that that was really a secondary consideration to the safety consideration of holding all of the particles of rock represented on the walls of that stope from falling and injuring men who are passing along the floor. ... The ease which it lends to the adaptability of mechanization is also a factor; but the prime consideration is always safety. ... That is the kind of consideration I am introducing here. So, that again is a factor, but I hold that they are contributory factors, and that the main and predominantly important factor is the use of a rock bolt as a safety measure.’’ ...

Imperial Oil Limited v. Minister of National Revenue, [1959] CTC 29, 59 DTC 1034

The determination of this question involves consideration of whether and to what extent the decision of the Supreme Court of Canada in Home Oil Company Ltd. v. ... The determination of this question involves consideration of whether subsection (4) of Section 1201 of the Regulations is ultra vires, as counsel for the appellant contended. ... In my opinion, they should be eliminated from consideration in the computation of the base for the appellant’s deductible allowance. ...

Raymond Ducharme v. Minister of National Revenue, [1978] CTC 2562, [1978] DTC 1414

Decision Chairman Snyder, also taking into consideration the percentage of work in relation to the volume of sales, assigned a value of $25,000 to the goodwill. ... The assets of A H Roy & Associates could not be taken into consideration in evaluating the goodwill. ... Could this relationship, which was an asset, be taken into consideration in determining the existence and value of the goodwill of Raymond Ducharme et Associés Inc? ...

Wain-Town Gas and Oil Company Limited v. The Minister of National Revenue, [1950] CTC 355

If it was a debt to be paid by the Government it introduces this consideration: Was it the intention of the Income Tax Acts ever to tax capital as if it was income? ... At page 145, Lord Wright states: "The question involved in the case is the question which has so often to be debated where property has been sold, namely, whether the consideration is a sum of money, though payable in instalments, or whether it is an annuity. ... By a policy of assurance effected by the appellant with an Assurance Society to provide for his son’s eduction, the Society, in consideration of six premiums of £90 each, paid annually between 1912 and 1917, agreed to pay him an annuity of £100 each year for seven years as from September 29, 1920. ...

2009 Ruling 2009-0312081R3 - Donation of Exchangeable Shares

With the exception of CCO, the Taxpayers acquired their Exchangeable Shares on XXXXXXXXXX, in consideration of their transfer to ACO of their Units. ... DCO acquired these Exchangeable Shares on XXXXXXXXXX, in consideration of its transfer to ACO of its Units. ... The relevant Taxpayer will receive, as consideration for the Exchange, the Exchange Consideration, which will consist solely of BCO Shares. ...

CanUtilities Holdings Ltd v. The Queen, 2003 TCC 193

That letter still referred to cash plus share consideration as the consideration for the purchase of ATCOR shares. ... It delayed the closing schedule, indicated cash consideration for the purchase of ATCOR shares (with a vendor option to receive share consideration) and stipulated that the consideration would be paid on a tax effective basis for all parties. ... I am satisfied that commercial considerations alone drove this decision. ...

Grandjamb v. Canada (Parks), 2019 FC 1023

In my view, as seen from the above, the Superintendent’s mandate is broad and is not restricted only to a consideration of s 50(4) of the WBNP Game Regulations. ... The Record of Decision indicates that, based on the above Parks Canada then conducted its analysis, setting out the key factors for consideration. ... The obligation to consult was a discrete consideration, although it could, and did, give rise to concerns with the proposed location of the trapping cabin. ...

10 August 2015 External T.I. 2015-0602751E5 - Capital gains deduction and section 84.1

We assume that you and your wife would acquire the shares of the Corporation directly from XXXXXXXXXX in consideration for a promissory note having a principal amount equal to the fair market value of the shares of the Corporation. ... In essence, section 84.1 of the Act will not have any immediate incidence if the amount of the non-share consideration and/or the paid-up capital of the shares received by you and your wife in consideration for the shares of the Corporation does not exceed the greater of the paid-up capital and the adjusted cost base of the Corporation shares. As described in paragraph 8 of IT-489R, paragraphs 84.1(2)(a) and 84.1(2)(a.1) of the Act provide rules for determining the adjusted cost base of Corporation shares for the purposes of determining the maximum non-share consideration or paid-up capital that you and your wife could receive from Holdco as consideration for the disposition of shares of the Corporation without any incidence under section 84.1 of the Act. ...

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