Search - consideration

Murji deposited $18,000 with the promoter (“as consideration for participating in the gifting arrangement”), the promoter then “transferred only $1,800 to On Guard [the charity] by depositing $18,000 in On Guard’s bank account and invoicing On Guard for $16,200” (para. 56). ...

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). ...

In consideration for the System, VLN was to provide to Pratt research and development (“R&D”) and engineering services (involving design, manufacture and testing) over three years. ...

The Queen, 2018 TCC 100, aff'd 2019 FCA 306-- summary under Paragraph 55(5)(b) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(5)- Paragraph 55(5)(b) safe income reduced by corporate income taxes An individual rolled his apartment building into a Newco in consideration for a mortgage assumption and shares with nominal paid-up capital, and then rolled those shares into a new Holdco. ...

There was a modification of an agreement for the making of a taxable supply in Canada to a person and an amount was paid to the registrant otherwise than as consideration for the supply. … Unfortunately for the appellant, the rules provided under paragraph 182(1)(b) … applied irrespective whether McKesson had claimed an input tax credit respecting the damages paid. ...

The unanimous shareholder agreement provided that its shares could not be transferred without the consent of all the “Special Majority Shareholders” including Pangaea, In the context of negotiations that led to the sale of the shares of Public Mobile to Telus, Pangaea and a resident shareholder (“Thomvest”) entered into an agreement on September 23, 2013 (the “Letter Agreement”) that provided that Thomvest would pay $3,000,000 as consideration for Pangaea’s agreement to execute a share purchase agreement. ...

The Queen, 2018 TCC 231-- summary under Paragraph (l) Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Financial Service- Paragraph (l) a car dealer who promoted and processed credit insurance to its customers was “arranging for” insurance A car dealer entered into a “Dealer Agreement” with a distributor of credit insurance products under which it was agreed that it would “up sell” the insurance products and assist the car customers in applying for the insurance in consideration for a commission of over 50% of the insurance premium. ...

D'Arcy J first found that each purchased interest qualified as a qualified investmetn, and then found that there was no income inclusion in the RRSP annuitants’ income under s. 146(9)(b), on the basis that such mortgage interests had a fair market value that equaled rather than being less than the cash consideration paid by the RRSPs therefor, stating (at paras. 64, 68) that: [T]he appellants purchased those interests as willing buyers from an arm’s length seller and... neither the appellants nor the seller (U-Have) were under any compulsion to buy or sell. ...

CIBC argued that these fees were (1) consideration for intangible personal property (the Aeroplan Miles) that were supplied by Aeroplan, and (2) that such IPP was exempted as being a supply of “gift certificates.” ...

Accordingly, he found that there was a transfer of property for insufficient consideration to which s. 160 applied at the time of the set-off transaction. ...