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The Queen, 2016 TCC 17-- summary under Subsection 136(1) Summary Under Tax Topics- Excise Tax Act- Section 136- Subsection 136(1) s. 136 applied to agreement to offer, at a distant date, to license sports complex to unidentified individuals 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. ...

The Queen, 2016 TCC 17-- summary under Section 2 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule V- Part VI- Section 2 agreement to licence sports complex in futre to City inhabitants was a real property supply 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. ...

. … In addition, the appliance and services were provided for and purchased together under a single contract for a single consideration. ...

The Queen, 2017 TCC 207, aff'd 2019 FCA 57-- summary under Adjusted Cost Base Summary Under Tax Topics- Income Tax Act- Section 54- Adjusted Cost Base ACB addition based on future amount payable rather than much lower FMV The taxpayer (Amoco) assumed a $225M loan that was due in perhaps 43-years’ time and that was effectively non-interest-bearing (as interest was tied to Beaufort Sea oil production) in consideration inter alia for the payment to it of $17.5 million by the debtor. ...

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. ...