Words and Phrases - "reasonably"

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Furukawa v. The Queen, 99 DTC 474 (TCC), aff'd 2000 DTC 6669 (FCA)

Various "sweeteners" provided by the issuer of what otherwise would be flow-through shares, namely, lifetime playing privileges and a building lot at a proposed golf course, and shares in another company, were items that a reasonable person would have very little expectation of getting and would attach little significance to and, in fact, did not appear to influence the taxpayer's decision to purchase the shares. Accordingly, they did not represent a return of consideration paid for the shares.

Rip TCJ. noted (at p.478) that "the term 'reasonably' implies an objective, rather than a subjective, examination of the facts."

In the Court of Appeal, Evans J.A. stated (at para. 41) that such objective standard

does not include benefits of very little intrinsic economic value or those that are in fact unlikely ever to be provided.

Words and Phrases
reasonably