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Subsection 146(9) of the Income Tax Act provides that if property is sold by an RRSP trust for consideration that is less than the fair market value of the property at the time of the sale, the difference between the consideration and the fair market value shall be included in the income of the annuitant in the year. ...

The Oxford English Dictionary defines a sale as an "exchange of a commodity for money or other consideration". Similarly, Black's Law Dictionary refers to a "transfer of property... for consideration". ...

Grisé January 22, 2002 Dear XXXXXXXXXX: Re: Contribution to Corporate Capital This is in reply to your letter of September 20, 2001, requesting our view on the cost to a corporation of property received by way of capital contributed by a major shareholder of the corporation for no consideration. ... In our view, the transfer of a property to a corporation by a majority shareholder of that corporation for no consideration would not result in a gift to the corporation, since the transaction would clearly result in a benefit to the shareholder in the form of an increase in the value of the shareholder's interest in the corporation. ...

Under this procedure, the Tax Court is not bound by legal or technical rules of evidence and is required to deal with appeals as expeditiously as the circumstances and considerations of fairness permit. ... Should your constituent's client submit a Form T2201 containing all the information required to his local Tax Services Office, due consideration will be given to whether he or she is entitled to the disability tax credit. ...

In a situation wherein an oil and gas exploration corporation has entered into an agreement with its arm's length employees whereby the corporation agrees to issue its "flow-through" shares to these employees for a specified consideration, upon such issuance, employment benefits will be recognized by each of these employees pursuant to paragraph 7(1)(a) of the Act. ... Furthermore, subsection 66.3(3) of the Act would also apply to deem these shares to have been acquired by these employees at a cost to them of nil, notwithstanding that they would have paid the specified consideration for the shares. ...

Paragraphs 6(3)(b) and (e) of the Act provide that an amount received by a person in satisfaction of an obligation arising out of an agreement made by that person and the payer immediately prior to, during or immediately after a period when the person was employed by the payer, is deemed, for the purposes of section 5, to be remuneration for the person's services rendered during the period of employment unless it cannot reasonably be regarded as having received in consideration or partial consideration for a covenant with reference to what the employee is, or is not, to do before or after the termination of employment. ...

Principal Issues: Whether subsection 76(1) is applicable to consider that payment of a demand note has been made when one non-resident sells that note to a second non-resident and receives a second demand note as consideration. ... The note receivable is in respect of a business carried on in Canada by the third non-resident and the consideration given by the second non-resident consists of a second demand note having a principal amount equal to the total of the principal amount of the original note plus the interest accrued thereon. ...

In our opinion, this will only occur where contributions have been made to the foreign plan by or on behalf of an employer or former employer of an employee in consideration for services rendered by the employee or, in some cases, where amounts have been contributed by a government. ... An annuity or other periodical payment made, esp. by a government, a company, or an employer of labour, in consideration of past services. ...

Reasons: Even though the quantum of the award depends upon the profitability of the corporate group for a given fiscal year, the arrangement is still "an agreement to issue shares" (albeit for no consideration) within the meaning of section 7. ... Also, the employee will not be entitled to a deduction under paragraph 110(1)(d) of the Act since the shares are acquired for no consideration. ...

Le contribuable est d'avis que, dans le calcul du « coût en main-d'oeuvre » de OPCO, seule la partie salaires des gestionnaires de Gesco relative aux honoraires devrait être tenue en considération. ... Réponse Quand des frais de gestion incluent des salaires, des frais généraux et d'autres items, nous sommes d'avis que le contribuable peut prendre en considération seulement les salaires dans le calcul du coût de la main-d'œuvre, telle que cette expression est définie à l'article 5202 du Règlement de l'impôt sur le revenu. ...