Search - consideration

La Reine, 2012 DTC 1076 [at at 2856], 2011 TCC 438 (Informal Procedure)-- summary under Paragraph 56(1)(o) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(o) Archambault J. found that "bursary" amounts that the taxpayer received from the University of Laval in connection with his postdoctoral fellowship at that university were not research "grants" (which had been judicially defined as financial assistance) because they instead represented consideration for (employment) services rendered by the taxpayer. ...

.)-- summary under Paid-Up Capital Summary Under Tax Topics- Income Tax Act- Section 89- Subsection 89(1)- Paid-Up Capital stated capital increase equal to principal of converted debt With respect to s. 23 of the Ontario Business Corporations Act … the effect of the conversion [of] a debt security into shares releases the corporation from liability for the principal amount of the debt security and that constitutes the consideration for the issuance of the shares. ...

Loss The taxpayer, a lawyer, who followed a practice of lending to start-up private companies and receiving shares of the companies (generally a 50% bloc) for nominal consideration, with a view to realizing gain after the companies had raised further funds through private placements or by going public. ...

The Queen, [1980] CTC 57, 80 DTC 6009 (FCTD), aff'd 81 DTC 5115, [1981] CTC 162 (FCA)-- summary under Comparison of Provisions Summary Under Tax Topics- Statutory Interpretation- Comparison of Provisions The Court was affected by the consideration that "it is more consistent that the same measure be applicable to subparagraphs (a) and (b) of section 126(1), than to have two different methods of calculating tax credits in the same section". ...

Ltd. (1942), 24 TC 392 in finding that inventory which the taxpayer acquired in consideration for issuing redeemable preferred shares with a par value of $603,081 had a cost at least equal to that amount. ...

The provision for the payment of such compound interest was "part of the consideration promised by the appellant in order to secure its capital. ...

The Queen, 84 DTC 6494, [1984] CTC 466 (FCTD), rev'd 85 DTC 5433, [1985] 2CTC 214 (FCA)-- summary under Paragraph 60(f) Summary Under Tax Topics- Income Tax Act- Section 60- Paragraph 60(f) A tuition fee was defined as "the monetary consideration (money or, money's worth of goods or services) payable to a pedagogue or school authority for enrolling a pupil or student in an instructional, training or educational lecture or course of lectures. ...

Canada, 2008 DTC 6513, 2007 FCA 16-- summary under Subsection 6(3) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(3) non-solicitation covenant taxable A lump sum received by the taxpayer, who was an investment advisor employed by a Canadian securities firm, on the termination of his employment was found to constitute consideration for his covenant (contained in the termination agreement) not to solicit clients given that "the non-solicitation covenant is at the heart of the termination agreement, which makes no mention of any sale of assets" (para. 16). ...

Canada, 2002 DTC 7061, 2002 FCA 212-- summary under Subsection 160(1) Summary Under Tax Topics- Income Tax Act- Section 160- Subsection 160(1) The taxpayers had been unsuccessful in establishing an alleged connection between service rendered by them and dividends on shares held by them, so that it was not necessary to determine, for the purposes of section 160, whether the work presumably performed could constitute valuable consideration for the issuance of dividends. ...

Bonner J. found that the contributions of the taxpayers to the shared costs of running the household were unrelated to the transfer to them of the condominium and, therefore, did not represent consideration for the transfer. ...