Search - consideration

The Queen, 2008 DTC 4390, 2008 TCC 401 (Informal Procedure)-- summary under Other Summary Under Tax Topics- General Concepts- Fair Market Value- Other The taxpayers purchased groups of paintings (approximately 40 or 50 in each year) for consideration that represented a substantial mark-up over the cost to the vendor ("CAAS") and that included a 15% retainer fee paid to CAAS for arranging for the donation of the paintings (almost immediately after their purchase by the taxpayers) to charities at an appraised value over three times the taxpayers' purchase price. ...

After reassessment of the sale in 1988, he accepted the Minister's valuation of the shares at $921,500 and replaced the consideration by promissory notes payable over 10 years in that amount. ...

The Queen, 2001 DTC 895 (TCC), aff'd on varied grounds 2003 FCA 22-- summary under Paragraph 214(3)(a) Summary Under Tax Topics- Income Tax Act- Section 214- Subsection 214(3)- Paragraph 214(3)(a) The taxpayer (a Canadian subsidiary of a U.S. corporation ("Gillette Boston")) contributed a 9.9% interest in a French partnership that was 90% owned by Gillette Boston, to a French subsidiary ("Oral B France") in consideration for shares. ...

" Bell T.C.J. found it unnecessary to incorporate any considerations of public policy in his reasons given that such criteria did not form unnecessary grounds for the decision of the Federal Court of Appeal in the Amway decision. ...

The Queen, 93 DTC 1043, [1993] 2 CTC 2681 (TCC)-- summary under Subsection 163(2) Summary Under Tax Topics- Income Tax Act- Section 163- Subsection 163(2) The taxpayer purchased a farm property for consideration comprising $166,824 plus his commitment to build a residence for the vendor with an agreed value of $76,649. ...

Accordingly, the $100,000 note was not consideration for the property. ...

Bowman TCJ. found that the debts were not extinguished by novation notwithstanding that the creditors acknowledged to CDL that no further consideration was owed to them in respect of the assigned indebtedness, and stated (at p. 1802): "A novation involves the creation of a new contractual relationship, generally where a debtor is released from its obligation to an obligee with the consent of the obligee and the assumption of the obligation by a third party so that a new obligation arises between the obligee and the third party. ...

Upon receiving the fifth and final cash instalment payment of the purchase price from the corporation, his brother purported in September 1997 to have the corporation retroactively issue two shares to the taxpayer in May 1995 and got the taxpayer to sign a second agreement providing for the purchase of those two shares by the corporation from the taxpayer in consideration for the four payments that the corporation had in fact made to him. ...

After receiving payment of the purchase price from the corporation, his brother purported to have the corporation retroactively issue two shares to the taxpayer and got the taxpayer to sign a second agreement providing for the purchase of those two shares by the corporation from the taxpayer in consideration for the two payments that the corporation had in fact made to him. ...

The Queen, 2015 DTC 1213 [at at 1374], 2015 TCC 265-- summary under Paragraph 248(8)(a) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(8)- Paragraph 248(8)(a) residuary beneficiary did not acquire as a consequence of death Owen J made a factual finding that a particular property (a house in the estate of the taxpayer's father) was purchased for cash consideration by her and her husband, as joint tenants, rather than being devised to her under her father's will. ...