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The Queen, 94 DTC 1663, [1995] 1 CTC 2788 (TCC)-- summary under Paragraph (j) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition- Paragraph (j) no disposition where right to repurchase at book value The transfer for nominal consideration by the taxpayer of 50% of his common shares in a corporation ("Les Entreprises") to a trustee in trust for a lender to Les Entreprises, with the right for the lender to receive any dividends on the shares while held in trust and with the right of the taxpayer to repurchase the shares of Les Entreprises from the trustee at their then book value provided that the loan to Les Entreprises from the lender as well as the previous loan from the taxpayer to Les Entreprises had both been repaid, was characterized by Lamarre Proulx TCJ. as not entailing a disposition of the shares of Les Entreprises by virtue of the predecessor of para. ...

Accordingly, they did not represent a return of consideration paid for the shares. ...

Hershfield J found that the amended purchase agreement entailed, at most, a supply of a co-ownership interest in the property by the appellant to her friend in consideration for her friend’s guarantee – and did not result in any interest in the condo also being supplied by the builder to the friend (so that the new housing rebate was not denied to the appellant). ...

Accordingly, he rejected the Minister's position that purported fees paid by Edison to Pouncey's company were disgused consideration for Hill's purchase of Edison's shares. ...

Miller J referred to a proposed amendment to s. 212.1(4) which explicitly added an exclusion where there was such non-resident ownership, and stated (at para. 97): [T]his proposed amendment…is a relevant consideration in ascertaining the purpose underlying the provision at issue in this appeal. ...

The Queen, 2016 TCC 17-- summary under Section 25 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule V- Part VI- Section 25 agreement to licence complex in future was not exempted becasue complex primarily used in commercial activity Tardif J found that two agreements under which Quebec City agreed to pay a $10M grant to Laval University for the expansion of its sports complex and the University agreed that the City populace would have access to the complex for 70% of its operating hours constituted a supply by the University in consideration for the $10M. ...

Ouimet J found that there was no “gift” and, thus, no s. 110.1(1)(a) deduction, as the taxpayer had received valuable consideration for its $9.3 million payments, being a release of “its obligation to negotiate in good faith to create [and fund] a limited partnership” (para. 46). ...

-resident registrant and a specified person, was assessed on the basis that its sales of recreational vehicles to Canadian dealers were made in Canada and that the consideration therefor included its freight transportation charges included on its invoices. ...

The royalty was paid in consideration for the seller providing to the buyer the seller’s “expertise, know-how, technique and experience in matters related to the Purchased Business.” ...

She then found that: The amount thus recognized as the consideration for Lockwood’s services “thus becomes the adjusted cost base of the AOI shares received in 2012. ...