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Accordingly, a double pipeline transaction was proposed under which each estate transferred its shares to a Newco in consideration for mostly a note in one case and mostly high-PUC preferred shares in the second. ...

CRA noted that the lease agreement was the only governing agreement between the dealer and the customer and that, generally, where the dealer and customer entered into a lease agreement, the entire monthly lease payment would be consideration for the dealer's single taxable supply of the vehicle by way of lease to the customer. ...

The shares of Subco2, which might be a significant subsidiary of DC, are split 50-50 between TC1 and TC2 on the butterfly, then TC1 sells its shares of Subco2 to TC2 for FMV consideration. ...

In rejecting a submission that such additional fees are part of the consideration for a single supply of the ultimate permits, CRA noted that “the provision of property and/or services by two or more suppliers generally indicates that multiple supplies are being made, even if the various supplies are provided together,” and that “many of the fees identified are payment for a separate supply, e.g., approval of a plan amendment or a condominium conversion.” ...

The other shareholders would transfer their Agrium and PotashCorp shares to two new subsidiaries of New Parent (“Agrium AcquisitionCo” and “PotashCorp AcquisitionCo”) in exchange for the delivery to them of New Parent shares (with the two AcquisitionCos simultaneously issuing shares to New Parent as payment for the New Parent share consideration). ...

Paris J stated that the quoted test “contemplate[s] a consideration of the right to receive the income of the trust over the entire lifetime of the trust rather than for each taxation year,” whereas here, after the death of the wife, the income of each trust went to a separate family rather than “ultimately accruing to the same group or class of beneficiaries.” ...

In this case, consideration should be given to requiring any excess investment earnings to be withdrawn from the Plan. ...

18 January 2017- 12:00am Bombardier India- Ahmedabad Income Tax Appellate Tribunal finds that technical services under the Canada–India Treaty, Art. 12 must entail know-how transfers Email this Content Art. 12(4)(b) of the Canada-India Treaty assimilates to royalties “payments of any kind… in consideration for the rendering of any technical or consultancy services…if such services…make available technical knowledge, experience, skill, know-how, or processes….” ...

Finally, CRA indicated that the assumption by the beneficiary of debt of a personal trust owing to a bank would not preclude s. 107(2) applying to the distribution provided that such assumption did not result in the trust ceasing to be a personal trust (having regard to the question, not discussed by CRA, of whether such assumption constituted consideration for the acquisition of a beneficial interest in the trust). ...

In order for the bank not to have a specified right, "the key consideration is that the secured property can be used only to repay the shareholder debt. ...