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In rejecting a submission that the money payable to High-Crest by the Department was not "government funding" as it was not for the purpose of making residential units in the facility available to seniors but, rather, was payable for the purpose of securing the services stipulated in the Service Agreement, Owen J stated (at para. 93): It is true that High-Crest was required to provide the Services as consideration for the payments it received from the Department. ...

The Queen, 2001 DTC 243 (TCC)-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) The taxpayer, who owned a portion of the shares of the holding company ("GH") which, in turn, owned an operating company ("GBC") utilized the enhanced capital gains exemption in connection with the sale of a cement plant operated by GBC through the following transactions: the taxpayer and the other shareholders of GH transferred a portion of their shares of GH to a newly-incorporated company ("Newco") in consideration for shares of Newco having a value of $500,000; GBC paid a dividend-in-kind of most of the cement plant assets (having a value of $1 million) to GH; GH redeemed the common shares held in its capital by Newco by transferring to Newco the assets it had received from GBC; and the shareholders of Newco's sold their interests in Newco to the purchaser (who also purchased the remaining cement-plant assets directly from GBC). ...

The Queen, 2013 DTC 1018 [at at 93], 2012 TCC 406, rev'd supra-- summary under Total Charitable Gifts Summary Under Tax Topics- Income Tax Act- Section 118.1- Subsection 118.1(1)- Total Charitable Gifts The taxpayer purchased timeshare units for cash (as to 1/9 of the consideration) and promissory notes (as to the balance), and then donated the units (which had a fair market value equal only to the cash portion of the "donation") to a registered charity. ...

The Queen, 2015 DTC 1141 [at at 908], 2015 TCC 146-- summary under Timing Summary Under Tax Topics- Income Tax Act- Section 9- Timing inducement payments received by lessor from manufacturer not income until potential repayment obligation quantified General Motors of Canada Limited ("GMC") made "residual value support payments" to the taxpayer ("GMAC"), which purchased vehicles subject to leases, in consideration for GMAC increasing the residual values (thereby reducing lease payments). ...

Tallon is to be deprived of the benefit of the prior decision for a subsequent year, it is only fair to her that the Court give careful consideration to the reasons in the prior case. ...

The Queen, 2012 DTC 1019 [at at 2575], 2011 TCC 520-- summary under Agency Summary Under Tax Topics- General Concepts- Agency Seeking to protect herself from being sued by her brother, the taxpayer transferred title to all her real properties for no consideration to corporations under her majority control. ...

The Queen, 2006 DTC 3006, 2006 TCC 256-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) The taxpayer transferred assets of a business to a partnership in what was intended to be an s. 97(2) rollover transactions in consideration for cash, promissory notes and assumption of debt ("boot") totalling an amount less than the cost amount of the transferred assets, and a Class "F" partnership interest stipulated to have a value equal to the balance of the purchase price. ...

The Queen, 2004 DTC 2604, 2004 TCC 280, briefly aff'd 2006 DTC 6351, 2006 FCA 171-- summary under A Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Undepreciated Capital Cost- A A partnership acquired Canadian rights to software in consideration for $960,000 in cash and an acquisition note in the amount of $12.15 million under which the interest was capitalized for the first nine years and thereafter quarterly instalments became due. ...

MNR, 96 DTC 1094, [1996] 1 CTC 2218 (TCC)-- summary under Paragraph 18(1)(e) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(e) The taxpayer, which ran a funeral home business and agreed with many of its customers to provide the required funeral services on each customer's death in consideration for a lump sum paid by the customer at or shortly after entering into the contract, also entered into a contract with the Fiducie du Quebec (the "Trustee") under which it was agreed that the Trustee would credit all sums of money delivered to it into a capital account, and credit 40% of all income earned on the capital account and a reserve account into that reserve account. ...

The trademarks were acquired by NN Life on the same day as the sale to the appellant and NN Life gave consideration to Underwriters equivalent in value to what it received from the appellant. ...