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The 2 nd subsidiary then sold its gainmaking shares to the 1 st subsidiary in consideration for a $10 million demand promissory note of the 1 st subsidiary (realizing a capital gain of approximately $10 million), and so on up the chain so that 12 of the 13 subsidiaries realized total gains of approximately $110 million and an addition to their capital dividend accounts of approximately $55 million. ...

Accordingly, the shares of the wives in S & D were purchased for cancellation in consideration for the transfer of lands of S & D to a corporation owned equally by the wives. ...

(CRA may have treated the non-equity consideration (“boot”) allocated to the non-goodwill assets as being in excess of their cost amounts, although the description of Diner J is unclear.) ...

The Court questioned the implicit assumption in the question that the NEC booking fees were consideration for a separate supply. ...

(theretofore, a wholly-owned subsidiary, and a successor by amalgamation to UNAC and the U.S. parent of UNAC, and holding Univar Canada) to (newly-incorporated) UHI for notes and common shares of UHI, UHI transferred those Univar Inc. shares to (newly-incorporated) UHC for notes and common shares of UHC, and Univar NV transferred its remaining shares of Univar Inc. to UHC for a note which then was assumed by UHI in consideration for issuing common shares. ...

Similarly, respecting the divestiture-related fees of Lazard Frères incurred up to board approval of a butterfly spin-off, these related to advice and approaches to potential third-party purchasers of the shares through which the laminated products business was held as well as to the ultimate sale (on a rollover basis) of the shares of that laminated products company to Novelis in consideration for the acquisition of (subsequently redeemed) preferred shares of Novelis, and the calculation of the Lazard Frères success fee did not represent a percentage of the value of those shares – so that those fees also were deductible under s. 20(1)(bb) as well as under s. 9. ...

In August 2006, the trustees of the Family Trust transferred a directly held portfolio on a rollover basis to a limited partnership (“CAL Equities”) in consideration for a limited partnership interest. ...

Pursuant to a Declaration dated March 31, 2007, the taxpayer, in consideration for the “Amount” of US$160,033,328 and CHF 80,000, relinquished to GI his claims to the PPU and GS, and assigned all his GH shares to GH. ...

In concluding instead (at para. 145) that “income taxes at the shareholder level should not be taken into consideration in the determination of the fair market value of the shares of Holdco,” Lafleur J stated (at para. 150): [T]here is no reason to believe that Holdco will be liquidated in the near future. ...

The conditions between mutually independent CFC and CAHPL could, however, include CAHPL situated within the Chevron group and CAHPL being subject to the direction of Chevron for the benefit of the Chevron group. 93 In such circumstances, were CAHPL seeking to borrow for five years on an unsecured basis with no financial or operational covenants from an independent lender, in order to act rationally and commercially and conformably with the interests of the Chevron group to obtain external funding at the lowest possible cost consistently with any relevant operational considerations, it would do so with Chevron providing a parent company guarantee, if such were available. 94 In the light of the evidence as to Chevron’s policy concerning external funding and its willingness to provide a guarantee to achieve that end the above is the natural and commercially rational comparative analysis when one removes the controlled conditions operating between CAHPL and CFC and replaces them with the condition of mutual independence. 95 In the circumstances there would have been a borrowing cost conformable with Chevron’s AA rating, which, on the evidence, would have been significantly below 9%. ...