Search - consideration

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. ...

., [1996] 2 CTC 2659, 97 DTC 607-- summary under Subsection 80(1) Summary Under Tax Topics- Income Tax Act- Section 80- Subsection 80(1) set-off The taxpayer, who was the general manager of a corporation ("HSS"), acquired debt of another corporation ("LTM") for consideration that was found by the Court to be nominal. ...

Ouimet J went on to find that the contemplation by the notes’ terms that they could be forgiven in the discretion of the employer had “no impact on the legal effect of the documents” and that it did “not matter what considerations led to the loans” (para. 60) (here, meeting the employer’s performance conditions). ...

The Queen, 2014 DTC 1197 [at at 3749], 2014 TCC 266-- summary under Subsection 247(2) Summary Under Tax Topics- Income Tax Act- Section 247- New- Subsection 247(2) highly discounted receivables purchased by non-resident affiliate were not "pig in a poke" Boyle J, after finding in McKesson that the taxpayer had been selling its trade receivable to its immediate Luxembourg parent (MIH) at discounts which were excessive from a transfer pricing perspective, recused himself from consideration of residual issues (respecting costs and the disposition of sealed documents) on the ground that he might no longer be considered to be impartial, as McKesson Canada, in its factum filed with the Federal Court of Appeal, had alleged that he was "untruthful and deceitful" in his reasons, stated "clear untruths" about him and alleged that he was not impartial (numerous paras. beginning at 4). ...

The Queen, 96 DTC 1207, [1996] 2 CTC 2347 (TCC)-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) interest not payable if contingent cash flow Part of the consideration given by the taxpayer for the purchase by it of a partnership interest was the assumption by it of a portion of the obligations of the vendor under a debenture of the partnership containing a specific covenant to pay interest on the principal amount thereof and on accumulated unpaid interest but containing a stipulation that payments of accumulated interest, current interest and principal were payable only out of 50% of the net cash flow of the partnership. ...