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In rejecting the Crown's position that such 20% share was taxable consideration for administrative, billing and marketing services supplied to the sleep physicians by MedSleep, Bodie J found that: The fee-sharing agreements were valid for tax purposes notwithstanding that, under provincial health care law, payments for physicians’ services could be made by the provincial health insurance plans to physicians only; and The fee-sharing agreements did not contemplate that MedSleep would provide the alleged admin and marketing services to the sleep physicians and they instead indicated that MedSleep was entitled to a portion of the professional fees generated from medical services provided to the patients. ... V-II-2 (the consideration for which was both its directly charged fees and its 20% share of the sleep physicians' fees), Bodie, J. found that MedSleep, in tandem with the sleep physicians, supplied institutional health care services referred to in both paras. ...

S. 237.1(7.4) provided that every person who, whether as principal or as agent, sells, issues or accepts consideration in respect of a tax shelter before the issuance of a tax shelter identification number (here, none was ever issued) is liable to a specified penalty. ... There also was a paucity of specific evidence as to the involvement of the four in “issuing anything” or “accepting consideration.” ...

S. 237.1(7.4) provided that every person who, whether as principal or as agent, sells, issues or accepts consideration in respect of a tax shelter before the issuance of a tax shelter identification number (here, none was ever issued) is liable to a specified penalty. ... Regarding the test of acceptance of consideration, even if the Crown had been able to demonstrate that the $40,000 alleged donation amount had actually flowed between the entities as alleged, it was unable to point to any specific acts performed by any of the four in accepting any monies as part of this alleged route of funds. ...

Tech/Pro transferred its net assets to Tiffany on an s. 85(1) rollover basis in consideration for preferred shares of a new class (“Same Class shares”) having a PUC and ACB of about $1.1 million and a redemption value of about $2.1 million. On the same day, the taxpayers transferred their Tech/Pro common shares to Tiffany in consideration for the issuance of further Same Class shares, with the s. 85(1) agreed amounts utilizing their respective lifetime capital gains exemption balances. ...

The Queen, 75 DTC 5274, [1975] CTC 472 (FCTD)-- summary under Shares Summary Under Tax Topics- General Concepts- Fair Market Value- Shares The taxpayer was granted the right to acquire 300,000 shares of a corporation in consideration of past services in June of 1967 and the shares were issued to him in December. ...

"The word 'wilfully' as used in the subsection under consideration, carries a distinct connotation of deliberate purpose and ulterior motive. ...

The Queen, 82 DTC 6045, [1982] CTC 30 (FCTD)-- summary under Evidence Summary Under Tax Topics- General Concepts- Evidence Statements in tax returns that "were not made inadvertently but only made following due consideration and professional advice... constitute statements against interest. ...

., [1961] 2 All E.R. 167 (HL)-- summary under Resolving Ambiguity Summary Under Tax Topics- Statutory Interpretation- Resolving Ambiguity [T]he prevailing consideration must be that the taxpayer should not be put to any risk of being charged with a higher amount of profit than can be determined with reasonable certainty. ...

., 53 DTC 1036, [1953] CTC 37 (Ex Ct)-- summary under Legislative History Summary Under Tax Topics- Statutory Interpretation- Legislative History Any doubt as to the meaning of s. 6(1)(o) was "entirely removed by a consideration as to how the law stood and the state of things existing at the time para. ...

Accordingly, the postage paid by it was 0-rated consideration. ...