Search - consideration

Was the consideration paid for an exempt supply, pursuant to section 7 of Part I of Schedule V? ... That is, the cottage owners paid consideration for use of the demise of the property (the lot). ... Therefore it is not the supply of land on which the consideration is given but the supply of services. [40] He submitted that the Appellant’s argument was based upon a consideration of section 6.1(e) of the Agreement. ...

The Appellant called no one from any municipality to establish that it paid any consideration for the services of SPCMA. ... This was consideration. Analysis and Decision [70] A number of peripheral matters were raised by Counsel during their argument. ... The Court is not satisfied that this evidence supported the contention that this was consideration for the activities of SPCMA. [93] The only funds that were received by SPCMA were the funds granted by CPIC and there was no evidence to suggest that any further consideration passed from the municipalities to SPCMA. ...

Fair Market Value at time of disposition: $900,000 Consideration Received: Description: 1,000 shares of 551360 Ontario Ltd. ... The critical fact is that the full consideration for the 5,001 shares of Drugs transferred by Mr. ... As stated earlier, where Section 85(1) (e.2) is of concern, fair market value of the total consideration becomes important. ...

After stating that “[p]rice is commonly defined to include consideration” and after adopting one of the definitions of “consideration” proposed by the learned author of Fridman’s The Law of Contract in Canada, 4 th ed. ... No, it does not affect the nature of the assumption of liability as consideration, though it may affect the value of that assumption ...

He submitted that the "true nature" of the $18.7 million payment was additional consideration on the ss. 97(2) rollover. ... As a simple matter of arithmetic there is no room for even a penny of additional consideration when the legal form of the transactions governs. ... It now wants to treat Operations as if it had received an additional $18.7 million worth of consideration for the business assets, which would give it $54.1 million worth of consideration for assets worth only $35.4 million. ...

More importantly no consideration was given to the rule against collateral attacks. ... In other words, if the Minister may not, in the performance of his assessment function, take into consideration facts that occur after the end of the taxation year, he may not, either, take into consideration judgments based on such facts. ... First, I am of opinion that the phrase “consideration that includes shares, ” in its plain and ordinary meaning, cannot refer to consideration that consists of a simple promise to issue shares. ...

The question as to the taxability of the said receipt of $17,000 is to be determined by a consideration of these facts and the relative provisions of the Income Tax Act, which then were: “3. ... The minute book of the respondent shows that the whole of the property was sold to the respondent in February, 1954 for a consideration of approximately $135,000. ... I may add, however, that quite apart from the above considerations, I would have been inclined to the view that the sum received was not a capital receipt. ...

The undersigned has advised Mr Gowling that, taking into consideration his salary, his responsibilities with your Company, and the inconvenience he incurred in moving to Montreal to accept employment with your Company, he is entitled to one year’s notice of termination or one year’s salary in lieu thereof. ... Taking into consideration Mr Gowling’s salary, his responsibilities with your Company and the inconvenience he incurred-in moving to Montreal to accept employment with your Company, he is entitled to one years notice, of termination or one year’s salary In lieu thereof. ... In consideration of the foregoing, I agree and undertake not to do anything that might harm or injure any of the said companies involved, including the principals, nor to do anything that may involve them in any difficulties. ...

Davies of a bank debit card and signed blank cheques on the Account constitute an exchange of consideration. ... No consideration or inadequate consideration flowing from the transferor to the transferee.   4.       ... Livingston provided adequate consideration to Ms. Davies for the deposit of these funds by Ms. ...

(i)         The Minister determined that both the $20,000 and $5,000 payments were remuneration received in consideration for a covenant with reference to what the employee is, or is not, to do before or after the termination of the employment ...     [3]      Subsection 6(3) of the Income Tax Act ("the Act") reads as follows:   6(3)      Payments to employer by employee – An amount received by one person from another (a)        during a period while the payee was an officer of, or in the employment of, the payer, or (b)        on account, in lieu of payment or in satisfaction of an obligation arising out of an agreement made by the payer with the payee immediately prior to, during or immediately after a period that the payee was an officer of, or in the employment of, the payer, shall be deemed, for the purposes of section 5, to be remuneration for the payee's services rendered as an officer or during the period of employment, unless it is established that, irrespective of when the agreement, if any, under which the amount was received was made or the form or legal effect thereof, it cannot reasonably be regarded as having been received (c)        as consideration or partial consideration for accepting the office or entering into the contract of employment, (d)        as remuneration or partial remuneration for services as an officer or under the contract of employment, or (e)        in consideration or partial consideration for a covenant with reference to what the officer or employee is, or is not, to do before or after the termination of the employment ... Is it in consideration, or partial consideration, for a covenant with reference to what the employee is, or is not, to do before or after the termination of the employment within the meaning of subsection 6(3) of the Act, or is it a capital payment in exchange for the sale of clientele?   ...