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The Queen, [1999] GSTC 119 (TCC)-- summary under Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Supply cancellation charges were consideration for a supply The registrant served retail travel agencies by booking and purchasing airline tickets for the agencies' customers, which resulted in the receipt by it of commissions from the airlines. ...

Before finding that this $15 charge was consideration for a financial service, Archambault J rejected (at para. 22) a submission of the registrant that it claimed payment from the credit card issuers as mandatary of the retail agencies: It was not established that Skylink had agreed with the retail agencies that it would act as their mandatary by requesting payment from the issuers. ...

The Queen, 2014 TCC 375-- summary under Evidence Summary Under Tax Topics- General Concepts- Evidence evidence of surrounding circumstances including income tax objective relevant to contract interpretation Before finding that the consideration for management services provided by a mutual fund trust manager to the trusts did not include special rebate distributions that the trusts were obligated to pay to large unitholders, and before finding (at paras. 72, 76) that the surrounding circumstances established that the parties intended to follow an ATR-65 structure, which required that the special distributions satisfy obligations of the trusts rather than the manager, Campbell J stated (at para. 45): [E]vidence respecting surrounding circumstances… will be limited to the objective evidence of the background facts at the time of formation and execution of the contract. … As noted in Sattva [2014 SCC 53], considering surrounding circumstances, as an interpretative aid, does not offend the parol evidence rule, which excludes evidence of the parties' subjective intentions and precludes considering evidence outside the words of the contract that would result in varying the contract in some manner. ...

The distribution to the taxpayer was found to be part of the consideration for the contribution of property made by it to the partnership. ...

., the taxpayer disposed of "a right to a right" of the sort described in what then was s. 66(15)(c)(ii)(B) when under a "farmout agreement" with Esso Resources Canada Limited, the taxpayer received from Esso the sum of $4.5 million in consideration for "... the right, licence and privilege of earning an interest in oil sands rights... ...

Richards in consideration for Ms. Richards’s guarantee – and as not resulting in any interest in the condo also being supplied by the builder to Ms. ...

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). ...

She was given no consideration for the funds. At the time, the appellant was aware that the taxpayer was having “issues” with CRA; the taxpayer had worked as an independent contractor and had failed to pay any tax from his business and had failed to file tax returns for several years. ...

Developer, respectively”) transferred individual resort condos (the “Vacation Homes,” which they had acquired in Canada, the U.S. and Mexico) to the Appellant (which was a non-share corporation resident in Canada) in consideration for the Appellant transferring occupancy rights to the Vacation Homes, in perpetuity to them. ...

Among other considerations, after October 1, 2010, anyone in Quebec wishing to issue an insurance product was required to hold an insurer's licence. ...