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We have calculated that our net pre-tax yield on this 7% Income Bond is 7.75%, i.e. after taking into consideration the Income Tax benefits and after deducting our cost of funds. ... He referred also to the reasons for judgment of Rand, J, in the Supreme Court of Canada in the matter of a reference as to the validity of Section 6 of the Farm Security Act, 1944, of the Province of Saskatchewan, reported in [1947] S.C.R. 394, where, at p 411, he states: “Interest is, in general terms, the return or consideration or compensation for the use or retention by one person of a sum of money, belonging to, in a colloquial sense, or owed to, another.” ... In the instant appeal, the acceptance of corporate shares as a part of the total consideration for granting a loan was integrated with the main business activity of the appellant—the loaning of funds. ...

Next there is the fact that the considerations which influenced Construction Aggregates to make the deal were to my mind trading considerations. ... There is also the fact that so far as appears Sensibar Dredging alone committed itself to and became party to the sale to McNamara and received the consideration. ... There is also the consideration that as between a parent and its wholly owned subsidiary what is in fact to be done as the act of the subsidiary as distinguished from that of the parent is very much a matter of internal arrangement and of decision by the parent. ...

In consideration of the payment by the appellant of $208 for the aforesaid 41,160 shares, he became entitled, at his option, to subscribe for an additional 83,533 at the same price per share, totalling $416, which sum he duly paid in November 1949. ... Ltd. whereby it would drill a well in consideration of Britalta giving its a checkerboard half-interest in the permit and by August the agreement was signed. ... I pass on to the consideration of a more positive test and one concerning which our jurisprudence provides more guidance in determining whether or not a transaction constitutes an adventure in the nature of trade. ...

The authorized capital stock consisted of 1,000,000 shares without nominal or par value, the maximum price or consideration permitted being $1.00 per share. ... It was a condition precedent to any payment to Scurry by the appellant that Scurry should have incurred exploration and drilling expenses and I can entertain no doubt that the money paid by the appellant to Scurry was in consideration for a transfer of an interest in land from Seurry to the appellant although that consideration was measured by the yardstick of the costs incurred by Scurry. ... I turn now to a consideration of the first issue of the two issues involved in these appeals, that is, the deductibility of the legal expenses incurred by the appellant as a consequence of the circumstances outlined above. ...

Commissioner of Taxes, [1927] A.C. 327, the assets of a partnership, including stock in trade, were sold to a limited company formed to carry on the business, the consideration being a lump sum payable in shares of the company. ... The truth is that the whole consideration was paid and received for the assets and rights granted as a whole, and no part of the consideration was paid or received for inventory alone or for equipment alone or for any other single asset or right by itself. ... At p. 504, Lord Radcliffe, with whom two other members of the House concurred, discussed the question as follows: “My Lords, with these considerations in mind, I must now say what I believe to be the right way to deal with the present case. ...

CIBC paid consideration in respect of the Loyalty Points awarded and administration costs (paragraph 13 of the Partial Agreed Statement of Facts as set out in paragraph 8 of the Reasons attached to the Rebate Judgment). ... The amount paid by CIBC for the administration of the loyalty program was also part of the consideration paid by CIBC for the single exempt supply made under the FSA and the LSA. [16] As a result, no GST was payable in relation to the consideration paid by CIBC to PC Bank under either the FSA or the LSA for the reporting periods from December 31, 2000 to December 30, 2002. ... For the same reason he declined to find that it would be an abuse of process for him to reconsider the issue of what was supplied by PC Bank to CIBC for the consideration paid by CIBC and, in particular, whether financial services were supplied by PC Bank to CIBC. ...

As noted above, the Memorandum prepared for the Minister’s consideration laid out the fairness arguments in a more expansive way than in the Applicant’s request for a remission to the Assistant Commissioner or in his direct request to the Minister. [70] The Memorandum also describes the circumstances and relevant considerations that may warrant a recommendation for remission. ... The Memorandum also explained the public interest considerations. [71] The Court does not agree that Barrs and Mockryke show the court’s openness to softening the principle that remission decisions are highly discretionary and that remission is not an extraordinary remedy. [72] In Barrs, the Federal Court of Appeal allowed the appeal of the Federal Court’s dismissal of Mr. ... The Minister did not fail to grapple with the Applicant’s submissions or the relevant considerations, including those set out in the FAA. ...

They also address the factors and considerations set out in Part II of the CRA’s Information Circular IC07-1R1, Taxpayer Relief Provisions, August 18, 2017 [the Guidelines] and makes recommendations. ... By referencing consideration of “other circumstances,” the Minister demonstrated that her consideration went beyond what the current Guidelines provide. [41] The Minister considered Mr. ... It is erroneous to state these considerations are limitations on the Minister’s discretion; rather, considering them ought to be properly understood as the Minister exercising her discretion and considering “other circumstances” not mentioned in the Guidelines. [42] Consideration of those circumstances may go to the reasonableness of the Decisions, but has no bearing on the manner in which the Minister conducted herself, given the absolute discretion she has in making these Decisions. ...

:—At the threshold of any consideration of the situs of shares of stock in relation to succession duty lie two recent rulings of the Judicial Committee. ... & W. 171; and that being so, we are remitted to the considerations by which the shares are localized in the place where they may be effectually dealt with. ... That consideration is the same for the transferee whether or not he receives a certificate directly from the registered shareholder. ...

.), the Federal Court of Appeal recognized that to vitiate a gift, a benefit or consideration must actually flow to the donor: … 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 (at 6032). ... Friedberg and later donated by him to the ROM, he was entitled to the deduction available for gifts of qualifying cultural property. [44] There was no issue or question of any expected benefit or consideration that would flow to Mr. ... There was no consideration of “the perceived worth of the benefit” to the shareholder or the “perceived worth of the land” that Mr. ...