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However, in my opinion, it more accurately reflects reality to say that Fiducie transferred 433 shares whose unit market value was $6,550, that the actual selling price of those shares was $2,836,423 (433 × $6550), an amount which, in fact, 404 obtained when it resold the shares to Keolis, and that the consideration given for this market value of $2,836,423 included two elements: a $2,602,637 promissory note, and 404's agreement to pay fees that Fiducie would have had to pay if 404 had not been interposed in the series of transactions carried out to sell the shares in question to Keolis. ...

In rejecting the submission, and finding that the amounts were deductible to the taxpayer, Archambault, J. stated (at para. 22-23): "... ...

In finding that such payments by RBC were the consideration for a taxable supply by CAIL of Points, Hershfield J stated (at para. 28): Everything CAIL did from being involved in establishing the terms of the credit facility to advertising the program was to promote the use of the card by the issuance of Points and that is what it was paid for – the issuance of Points. ...

See summaries under s. 118.1 – total charitable gifts and s. 104(1). ...

") – earned management fees and rental fees from W.L. In 2003, the taxpayer lent $3.5 million to an arm's length supplier of specially prepared boards ("Interact") secured by patents held by Interact's principal ("Cable"). ...

Following a proposal by the Minister, over six months following the death of the taxpayer’s husband, to assess the taxpayer for trust income, she executed a form purporting to confirm that she had disclaimed her entitlement to income from the trust – and took the position that the distributions to her were of taxed capital. ...

Following a proposal by the Minister, over six months following the death of the taxpayer’s husband, to assess the taxpayer for trust income, she executed a form purporting to confirm that she had disclaimed her entitlement to income from the trust – and took the position that the distributions to her were of taxed capital. ...

Dussault J. found that the buy-back right represented an amount that "may reasonably be expected, having regard to statements and representations made in respect of the interest, to be received or enjoyed by a person (... 'the purchaser')... which receipt or enjoyment would have the effect of reducing the impact of any loss that the purchaser may sustain in respect of the interest" and found that the buy-back right could also be concluded to be more specifically referred to in Regulation 231(6)(c). ...

. … I am unable to see how the broad wording of the relevant provisions and the interpretation thereof by the Federal Court of Appeal that the wording is mandatory and should be strictly enforced, and which requires that the ITC claimant have the registration number assigned to the supplier, should result in any different outcome in this case ...

See summary under General Concepts – Sham. ...