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His contention, that this transfer (made in consideration for a credit to his shareholder loan account) was not made in the course of commercial activity and was thus not a taxable supply, was directly contradicted by his testimony that his intention when acquiring the equipment was "to make money with it. ...

") that was mostly owned by Chen but in which she held 5% of the common shares and for consideration that in her case was paid in cash. ...

In finding that the taxpayer was not entitled to any deduction under s. 110(1)(d) in respect of a lump sum she received in the following year in consideration for the waiver of her rights under the stock option, Lamarre Proulx TCJ. found that the shares subject to the option could not be prescribed shares when they could never be issued or purchased. ...

In finding that the taxpayer was not entitled to any deduction under s. 110(1)(d) in respect of a lump sum she received in the following year in consideration for the waiver of her rights under the stock option, Lamarre Proulx TCJ. found that the shares subject to the option could not be prescribed shares when they could never be issued or purchased. ...

The Queen, 2009 DTC 912, 2009 TCC 295-- summary under Subsection 143.2(7) Summary Under Tax Topics- Income Tax Act- Section 143.2- Subsection 143.2(7) Promissory notes owing by the taxpayers, which were consideration for their acquisition of units of a limited partnership, provided that the interest thereon was to be paid by way of set-off against distributions otherwise payable by the partnership to the taxpayers. ...

The Queen, 2009 DTC 912, 2009 TCC 295-- summary under Subparagraph 152(4)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4)- Paragraph 152(4)(a)- Subparagraph 152(4)(a)(i) reliance on professional opinions for technical matter After finding that the taxpayers did not have limited recourse amounts for promissory notes they gave as consideration for the limited partnership units offered with the offering memoranda given the absence of any arrangements for payment of interest on the notes on a timely basis and other deficiencies, Campbell, J. found (at para. 104) that the taxpayers could not be reassessed beyond the normal reassessment period: "I believe they were acting in a reasonable and prudent manner in placing reliance on the various professional opinions before making a decision to invest and should not be held to a higher standard. ...

Minister of National Revenue, 91 DTC 696, [1991] 1 CTC 2679 (TCC)-- summary under Subsection 227.1(3) Summary Under Tax Topics- Income Tax Act- Section 227.1- Subsection 227.1(3) In 1981 the taxpayer sold all his shares of the corporation in consideration for a secured debenture of the corporation, but remained on as a passive (and inactive) director. ...

It was consideration for the cancellation of the unexercised Options. ...

Kempo TCJ. found that what then was s. 245(2) did not apply to these transactions (and to similar loss utilization transactions) because no "benefit" could arise to the taxpayer from its purchase of the shares of the holding company where it had provided fair market value consideration. ...

In preferring (subject to an adjustment made by the Court) the taxpayer's method of computing a bad debt deduction from the income of the partnership for that period to that made by the two remaining partners, Rip T.C.J. noted that the two remaining partners did not give much thought or consideration to whether a debt was good, doubtful or bad and did not consider a debt to be bad if the client was still a client of the firm and was not yet bankrupt; whereas the taxpayer made a very conscious and deliberate attempt to determine which of the partnership's debts were good, doubtful or bad. ...