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James' Chambers in consideration for a percentage of the gross fees of each barrister, did not hold an "office". ...

Canada, 2003 DTC 5225, 2003 FCA 128-- summary under Exempt Receipts/Business Summary Under Tax Topics- Income Tax Act- Section 9- Exempt Receipts/Business non-taxable non-compete Consideration received by the taxpayer for giving a non-compete covenant on the sale of shares of companies owned by him directly or through holding companies was found to be a non-taxable capital receipt. ...

Canada, 2003 DTC 5225, 2003 FCA 128-- summary under Expense Reimbursement Summary Under Tax Topics- Income Tax Act- Section 9- Expense Reimbursement Consideration received by the taxpayer for giving a non-compete covenant on the sale of shares of companies owned by him directly or through holding companies was found to be a non-taxable capital receipt. ...

W4N selling its intellectual property, goodwill and some of its other business assets to EMC for consideration including two “capital dividend” notes totaling $22 million (which were later distributed) and a “Balance Note” for $19.75 million. Souty and Virtuose selling special voting shares of W4N to EMC Canada for nominal consideration so as to effect an acquisition of control of W4N and a resulting year end. The balance of the shares of W4N now being sold directly, or through a sale of the balance of the Virtuose shares, for cash consideration of around $14 million. ...

The predecessor of s. 78(1) accordingly did not apply to a non-arm's length sale of land inventory for a consideration to be paid over a 7-year period. ...

Among other things, none of the stipulated consideration was ever paid by the holding company and the directors of READ did not approve the transfer as required by the articles. ...

., 97 DTC 55, [1997] 2 CTC 2184 (TCC), briefly aff'd on procedural grounds 2000 DTC 6060 (FCA)-- summary under Section 3 Summary Under Tax Topics- Income Tax Act- Section 3 Lump sums received by individual vendors of shares in consideration for their entering into non-competition agreements with the purchaser were characterized as being for their surrender of a potential source of profit and, therefore, represented capital receipts that were not taxable under s. 3. ...

., 97 DTC 55, [1997] 2 CTC 2184 (TCC), briefly aff'd on procedural grounds 2000 DTC 6060 (FCA)-- summary under Exempt Receipts/Business Summary Under Tax Topics- Income Tax Act- Section 9- Exempt Receipts/Business Lump sums received by individual vendors of shares in consideration for their entering into non-competition agreements with the purchaser were characterized as being for their surrender of a potential source of profit and, therefore, represented capital receipts that were not taxable under s. 3. ...

., 97 DTC 55, [1997] 2 CTC 2184 (TCC), briefly aff'd on procedural grounds 2000 DTC 6060 (FCA)-- summary under Expense Reimbursement Summary Under Tax Topics- Income Tax Act- Section 9- Expense Reimbursement Lump sums received by individual vendors of shares in consideration for their entering into non-competition agreements with the purchaser were characterized as being for their surrender of a potential source of profit and, therefore, represented capital receipts that were not taxable under s. 3. ...

The Queen, 2001 DTC 1094 (TCC), aff'd supra 2003 DTC 5298 (FCA)-- summary under A Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Undepreciated Capital Cost- A Rip T.C.J. accepted the position of the Minister that a note issued by a partnership as part of the consideration for the purchase by it of software "engines" was a contingent note because interest and principal on it were payable only out of stipulated percentages of gross profits generated by the software. ...