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The numerous “purchasers,” in consideration for a lump sum, each acquired the right, after making a reservation, to use a residence of the particular quality level (1 to 5) for which they had paid, for up to 21 days a year during the term of approximately 50 years (plus for a further 14 nights on payment of a modest charge). ...

Accordingly, he found that there was a transfer of property for insufficient consideration to which s. 160 applied at the time of the set-off transaction. ...

Dewar J also commented obiter on the subsequent enactment of s. 256(5.11), stating: I make no comment about whether that amendment if applicable in 2007- 2011 would have changed the result which I have come to on this appeal, except to say that it would have merited further consideration. ...

28 August 2019- 12:28am CRA treats bitcoin mining as a barter exchange of services for bitcoin Email this Content After finding that “Bitcoin received by a miner to validate transactions is consideration for services rendered by the miner,” and that “As cryptocurrencies are not legal tender, it follows that when a cryptocurrency is used to pay for, or is received as payment for, goods or services, this is treated as a barter transaction,” CRA stated: [W]here a taxpayer who is in the business of Bitcoin mining receives Bitcoin as a result of their mining activities, they must bring into income the value of the services rendered or the value of the Bitcoin received, whichever is more readily valued. ...

., it was consideration for the disposition of the leasehold interest (used as a principal residence) that the tenant had acquired in 2013 and held since then. ...

After referring to the Quebec equivalent of s. 67, and in finding that the taxpayer had not met its burden of establishing that such assessments were incorrect, Allen JCQ stated: How can the plaintiff challenge the presumption of correctness of the notices of assessment where the 7.89% rate, considered to be reasonable and adopted by the defendant, falls within the range that its own expert considered to be a reasonable rate based on the current rates in the market for obligations with similar considerations and risks during the period in litigation? ...

1 November 2019- 12:40am CRA finds that a GST/HST-registered non-resident marketer using services of a Canadian subcontractor was thereby making supplies in Canada Email this Content A registered non-resident (NR) does not itself have any presence in Canada but uses a resident (sub)contractor (RC) to provide marketing and soliciting services (in the credit card processing line of business) to a resident Canadian company in consideration for commissions. ...

. … [T]he FMV of a supply of a management or administrative service may not necessarily always correspond to the consideration paid for such a service. … General partners can use whichever method they would like to determine FMV. ...

17 November 2019- 11:52pm CRA rules on butterfly split-up of rental property into co-ownership arrangement Email this Content CRA provided the usual butterfly and other rulings on a butterfly split-up of a DC holding rental property between two transferee corporations (the TCs) for two unrelated families, with undivided interests in the real estate being transferred to each TC in consideration for the assumption of liabilities (in such proportions as to ensure satisfaction of the pro rata distribution requirement) and for voting preferred shares, which were promptly redeemed for notes. ...

Second, a U.S. subsidiary of Encana would be distributed out of Encana in consideration for the assumption of debt and as Encana-share redemption proceeds, and Ovintiv would then drop Encana (which previously had been converted into a B.C. ...