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However, after stating (at para. 22) that he accepted the conclusion in Sherway Centre that “an amount paid as compensation for the use of money for a stipulated period can be said to accrue day-to-day,” McEwen J found that the Discount Fee constituted interest, stating (at para. 45): … [I]t is my view … the Discount Fee meets the three … elements of interest: it is consideration or compensation for the use or retention of money owed to ClearFlow; it related to the principal amount; and, it accrued over time (literally day-to-day). ...

. … Whether the interests of the applicants in Talison Lithium also passed the principal asset test, for the purposes of s 855-25(1)(b), requires consideration of whether 50% or more of the market value of the assets of Talison Lithium were attributable to Australian real property. ...

The Queen, 2018 TCC 102, aff'd 2020 FCA 115-- summary under Subsection 97(2) Summary Under Tax Topics- Income Tax Act- Section 97- Subsection 97(2) the starting ACB of a partnership interest was determined exclusively under s. 97(2)(b)/ no requirement to issue units In 2003 and 2004, the taxpayer (“Iberville”) contributed shopping centres worth $130M and with a cost base of $14M and received non‑share consideration or boot of $8.5M. ...

., close to half) to a wholly-owned personal holding company (a “Holdco”) in consideration for preferred shares which, after giving effect to the joint election made under the Quebec equivalent of s. 85(1) (limiting the taxable capital gain recognized by him in each year to $250,000) had a paid-up capital equal to their deemed cost. ...

It only leaves for consideration the consequences of a reduction in capital. ...

Colitto for nominal consideration. In 2016, the Minister assessed Ms. ...

Respecting 2010. after quoting with approval (at para. 17) the statement in Ivan Cassell that the applicable test under the PSB test was “whether, taking into consideration all the circumstances, [the specified shareholder] would reasonably be regarded as carrying on a business on his own account if [his personal corporation] did not exist,” Visser J stated (at paras. 27-28): Ms. ...

Rossiter CJ also found that there was an exchange of legal consideration, stating (at para. 132): Black’s direct advancement of funds to International on Inc.’s behalf is not a bar to a loan existing between Black and Inc. ...

In rejecting the taxpayers’ submissions that “all circumstances, including personal family circumstances and personal estate planning goals must be considered” (para. 90) and that the income and loss allocation methodology could be supported from the standpoint of estate planning objectives, he stated (at paras. 94, 97): [T]he reasonable business person would only consider factors relevant to their own business considerations having regard to their own business interest. ...

Singh for nominal consideration of two dollars, at a time that Mr. Singh’s tax debt was still owing. ...