Search - consideration

., 73 DTC 5354, [1973] CTC 434 (FCA), briefly aff'd 76 DTC 6312, [1976] CTC 415 (SCC)-- summary under Subsection 88(1) Summary Under Tax Topics- Income Tax Act- Section 88- Subsection 88(1) The word "distributed" was held not to include a sale of accounts receivable for valuable consideration. ...

The Queen, 94 DTC 1765, [1995] 1 CTC 2298 (TCC)-- summary under Subsection 70(6) Summary Under Tax Topics- Income Tax Act- Section 70- Subsection 70(6) A transfer of shares to the wife of the deceased in consideration for cash and set-off of debts owing to her by the estate occurred pursuant to a purchase transaction rather than as a consequence of the death of the deceased. ...

Sexton J.A. stated (at p. 7119) that "Technical Notes are not binding on the courts, but they are entitled to consideration." ...

The bulk of the total consideration was allocated to the building. ...

.), rev'd [1980] BTC 239 (HL)-- summary under Paragraph 69(1)(b) Summary Under Tax Topics- Income Tax Act- Section 69- Subsection 69(1)- Paragraph 69(1)(b) "[T]he ordinary primary meaning of 'gift' is a voluntary transfer of property made without consideration." ...

MNR, 58 DTC 676 (TAB)-- summary under Subparagraph 20(1)(p)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(p)- Subparagraph 20(1)(p)(i) The consideration received by the taxpayer on the sale of a theatre, which gave rise to recapture of depreciation to it, included the assignment to it of a debt owing by the purchaser. ...

The Queen, 82 DTC 6311, [1981] CTC 421 (FCTD)-- summary under Subsection 174(3) Summary Under Tax Topics- Income Tax Act- Section 174- Subsection 174(3) Notwithstanding the desire of counsel both for the taxpayer and the Crown to limit discussion to the narrow question before the Court, the Court is entitled "to widen the discussion sufficiently to embrace the true nature of the transaction [under consideration] and the circumstances surrounding it". ...

The Queen, 2012 DTC 1106 [at at 3044], 2012 TCC 86-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt past services Margeson J. accepted (at para. 99) that employees to whom the taxpayer issued shares in payment of bonuses to them gave consideration equal to the full value of those share "on the basis of past unremunerated services rendered to the Appellant. ...

The Queen, docket 2001-862-GST-I (TCC) (Informal Procedure)-- summary under Financial Service Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Financial Service A fee received by the taxpayer for agreeing not to bid for the assets of an insolvent corporation did not represent consideration for a financial service. ...

Customs and Excise Commissioners, [2000] BTC 5153 (QBD)-- summary under Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Supply The surrender of hand guns by the taxpayer to the government and the receipt of compensation therefor constituted a supply for consideration given that there was a transfer of title to the government. ...