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The King, 2023 TCC 45, aff'd 2025 FCA 27-- summary under Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Supply Bell Canada received single supplies of electricity from its Ontario electricity suppliers Bell Canada was required as a result of ETA s. 236.01 and the related regulation to recapture 100% of the input tax credits that it claimed in respect of the 8% Ontario HST that it paid on the consideration for the supplies to it in Ontario of electricity. ...

., cancellation) of the non-compete The taxpayer made a series of demands for parties to a non-compete agreement (that it had received in connection with its acquisition of a business) to comply with the agreement and, following negotiations and before the commencement by it of an action, it was agreed that it would be paid a lump sum in consideration for the cancellation of the non-compete agreement. ...

Micsau transferred its Class D preferred shares of 3295940 to a Newco formed by it (“4244”) in exchange for Class D preferred shares of 4244 having the same full FMV/ACB. 3295940 transferred its shares of Holdings to 4244 on a partial s. 85(1) rollover basis in consideration for $57M of Class D preferred shares of 4244 (with $57M being the agreed amount, so that it thereby realized a capital gain of $53M) and for common shares having a nominal cost pursuant to s. 85(1)(h). ... On August 12, 2004, Micsau transferred its shares of 4244 to 3295940 in consideration for 31.5M preferred shares of 3295940, with no gain being realized. ...

The consideration for a sale for the most part comprised a "Closing Payment" paid by the purchaser trust out of the proceeds of commercial paper issuances and "Deferred Amounts" representing most of the cash subsequently generated to the trust from the purchased mortgages net of all other outlays. ...

The Queen, 2014 DTC 1162 [at at 3556], 2014 TCC 30-- summary under Section 67 Summary Under Tax Topics- Income Tax Act- Section 67 leveraged purchase of seismic data at arm's length was presumptively reasonable On December 31, 1993, the taxpayer and other parties to a joint venture acquired (through the joint venture operator ("507") the rights to exploit a body of seismic data (which had been previously sold the same day for $805,000 in cash) in consideration for $975,000 cash and a $5,525,000 promissory note (payable only out of 50% of net licensing revenues and 20% of any production cash flow generated out of any petroleum rights acquired by the joint venture)- which the Minister conceded was not a contingent liability. ...

Among other factual considerations were that: the two individuals controlling the taxpayer de jure also were the key directors and officers of Lyrtech (which had a seven-person board) and of other group companies, and they were not independent directors of Lyrtech; the taxpayer had virtually no revenues, was under-capitalized, and depended on Lyrtech to finance its activities either directly or through guarantees; and Lyrtech determined what R&D work the taxpayer would conduct. ...

After Revenue Quebec indicated (at the end of 2008) that it would deny the appellant's claim (made for its quarterly reporting period ending on 31 January 2007) under s. 231 on the basis that the situation instead had called for a claim under s. 232 (apparently based on viewing the February 2007 agreement as an adjustment to the consideration), the appellant (in January 2009) entered into a write-off agreement with Flora, issued a credit note to Flora, and claimed a credit under s. 232(3) for the GST of $103,440 in its return for the reporting period ending on 31 January 2009. ...

As contemplated in the Offering Memorandum, two weeks later the partnership transferred its assets to the corporation in consideration for preferred shares, with the preferred shares then being distributed to the partners on the dissolution of the partnership. ...

JC then transferred his shares of PC to a newly-incorporated holding company ("601") in consideration for a promissory note of 601 in the same amount and the issue of common shares. ...

Following a determination that the cement plant would be sold to an arm's length purchaser ("Lafarge") in transactions which sought to utilize the enhanced capital gains exemption, the following transactions were implemented: 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 which it had received from GBC; and the shareholders of Newco sold their interests in Newco to the Lafarge (who also purchased the remaining cement-plant assets directly from GBC). ...