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Results 21 - 30 of 584 for consideration
SCC
Minister of National Revenue v. Royal Trust Co. et al., [1949] SCR 727
In consideration of these renunciations, Mrs. Fleet was promised $20,000. ... The decisive consideration is the meaning to be attributed to s. 3 (1) (j) of that Act. ... I agres that although marriage is a valuable consideration it is not consideration in money or money's worth. ...
SCC
Minister of National Revenue v. The Royal Trust Company, and Dame Helena Dawes,, [1950] CTC 21
In consideration of these renunciations, Mrs. Fleet was promised $20,000.00. ... The decisive consideration is the meaning to be attributed to section 3(1) (j) of that Act. ... I agree that although marriage is a valuable consideration it is not consideration in money or money’s worth. ...
SCC
Beulah Gorkin and Jack Adilman, as Administrators of the Estate of Nathan Adilman, Deceased v. Minister of National Revenue, [1962] CTC 245
It is said that the transaction is not a gift within the meaning of the statute because a consideration was given. ... It refers to ‘‘ property transferred for partial consideration in money or money’s worth paid or agreed to be paid’’. ... It involved a transfer of property for a partial consideration agreed to be paid. ...
SCC
Judgment Accordingly. Beulah Gorkin and Jack Adilman, as Administrators of the Estate of Nathan Adilman, Deceased v. Minister of National Revenue, [1962] CTC 244, [1962] DTC 1166
It is said that the transaction is not a gift within the meaning of the statute because a consideration was given. ... It refers to ‘‘ property transferred for partial consideration in money or money’s worth paid or agreed to be paid’’. ... It involved a transfer of property for a partial consideration agreed to be paid. ...
SCC
Gorkin v. Minister of National Revenue, [1962] SCR 363
It involved a transfer of property for a partial consideration agreed to be paid. ... It is said that the transaction is not a gift within the meaning of the statute because a consideration was given. ...
SCC
Robert B. Curran v. Minister of National Revenue, [1959] CTC 416
However, the payment of $250,000 w as made for personal service only and that conclusion really disposes of the matter as it is impossible to divide the consideration. ... The House of Lords held that so much of the payment as represented consideration for a reduction in salary was income and subject to tax, but that the consideration received by the taxpayer for commutation of his pension rights was not income. ... However, the essence of the matter was the acquisition of services and the consideration was paid so that those services would be made available. ...
SCC
Curran v. Minister of National Revenue, 59 DTC 1247, [1959] S.C.R. 850
The payment was made for personal service only and that conclusion really disposed of the matter as it was impossible to divide the consideration. ... The essence of the matter was the acquisition of services and the consideration was paid so that those services would be made available. ... The House of Lords held that so much of the payment as represented consideration for a reduction in salary was income and subject to tax, but that the consideration received by the taxpayer for commutation of his pension rights was not income. ...
SCC
The Queen v. Golden et al., 86 DTC 6138, [1986] 1 CTC 274, [1986] 1 SCR 209
This was perceived as a determination to be approached from the point of view of the vendor rather than the purchaser as it is consideration for disposition, not consideration for acquisition, that the section specifies. 18. ... Whereas s. 20(6)(g) applied in circumstances where an amount received by a taxpayer could reasonably be regarded as being in part consideration for the disposition of depreciable property and in part consideration for the disposition of something other than depreciable property, s. 68 applied only "in circumstances where an amount received by a taxpayer can reasonably be regarded as being in part the consideration for the disposition of any property and as being in part consideration for something else other than any property " (emphasis in the original). ... Estey J. said at p. 332: In the opening portions of rule (g), provision is made for the allocation of so much of the consideration as can reasonably be regarded as being in part the consideration for the disposition of depreciable property and for the allocation otherwise of that part of the consideration which can be reasonably regarded as having been paid for "something else". ...
SCC
R. v. Malloney’s Studio Ltd., 79 DTC 5124, [1979] CTC 206, [1979] 2 S.C.R. 326
In the opening portions of rule (g), provision is made for the allocation of so much of the consideration as can reasonably be regarded as being in part the consideration for the disposition of depreciable property and for the allocation otherwise of that part of the consideration which can be reasonably regarded as having been paid for “something else”. ... When this factual situation occurs, the rule then permits the allocation of that part of the consideration received in the total transaction to depreciable assets as “can reasonably be regarded as being in part the consideration for disposition of depreciable property of a taxpayer”. ... Only the deed conveying the land on which no buildings were then located, was delivered upon receipt of the consideration of $280,000. ...
SCC
Wilder v. Minister of National Revenue, 52 DTC 1014, [1951] CTC 304, [1952] 1 SCR 123
:—On February 6, 1932, the appellant sold to Wilder Norris Limited certain assets for the following consideration:— 1. ... I therefore turn to a consideration of the authorities. In Secretary of State v. ... Whether or not they were capital sums had to be determined by a consideration of the substance of the transaction. ...