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The Queen, 2015 DTC 1103 [at at 614], 2015 TCC 80 (Informal Procedure)-- summary under Effective Date Summary Under Tax Topics- General Concepts- Effective Date consideration for transfer to shareholder adjusted without price adjustment clause An individual shareholder of a corporation ("B&N") thought that he was the beneficial owner of his home, but everyone else, including his accountants (and ultimately the Tax Court) considered that it was beneficially owned by B&N. ...

The definition of a capital beneficiary included individuals (subject to specified exclusions) had made written application to the Trustee for consideration for inclusion as a Capital Beneficiary, had made charitable donations to one or more registered charities in the calendar year of such application and received receipts in prescribed form for such donations. ...

The next day, the taxpayer sold these shares to a partnership of which his wife was a general partner and three of his children held a 99% limited partnership interest in consideration for a $487,000 promissory note of the partnership bearing interest at the rate prescribed for purposes of s. 74.5. ...

The Queen, 99 DTC 150, [1999] 1 CTC 2498 (TCC)-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) The taxpayer gifted a portion of his common shares of a family small business corporation to a trust for his children utilizing the rollover provisions of former s. 73(5) and then, approximately one month later, repurchased the shares in consideration for an interest-bearing promissory note. ...

It was appropriate to allocate 25% of the fees paid to the casino operator as consideration for the exempt cheque-cashing service, and to treat the balance as taxable. ...

., purchased all the shares of Greenleaf from Ford U.S. for consideration of $1, and purchased the debt at only a slight discount to the amount owing, so that the debt-parking rules in ss. 80.01(6) to (8) did not apply. ...

., purchased all the shares of Greenleaf from Ford U.S. for consideration of $1, and purchased the debt at only a slight discount to the amount owing, so that the debt-parking rules in ss. 80.01(6) to (8) did not apply. ...

., purchased all the shares of Greenleaf from Ford U.S. for consideration of $1, and purchased the debt at only a slight discount to the amount owing, so that the debt-parking rules in ss. 80.01(6) to (8) did not apply. ...

Bueti, who was entitled to receive 1/3 of the residue of estate of her father (who died in August 1999), was found to have purchased, as joint tenant with her husband, a property (a house) included in her father estate for consideration of $50,000, which was less than its fair market value at the time of the July 2000 purchase. ...

The Queen, 2015 TCC 191 (Informal Procedure)-- summary under Tax Shelter Summary Under Tax Topics- Income Tax Act- Section 237.1- Subsection 237.1(1)- Tax Shelter shelter based on potential interests rather than what actually was acquired The taxpayers entered an arrangement with a corporation ("Blue Hill") in order to deduct Canadian resource expenditures from income: the taxpayers paid $2 for an option to acquire an interest in mineral claims owned by Blue Hill; in exercising the options, the taxpayers agreed to engage Blue Hill to incur CRE on their behalf in consideration for promissory notes Lyons J found (at para. 42) that the taxpayers were not required by Blue Hill to pay the promissory notes. ...