Search - consideration

Results 321 - 330 of 417 for consideration
TCC (summary)

Vivaconcept International Inc. v. The Queen, 2013 TCC 336 -- summary under Subsection 231(1)

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. ...
TCC (summary)

Teelucksingh v. The Queen, 2011 DTC 1052 [at at 272], 2011 TCC 22 -- summary under Section 96

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. ...
TCC (summary)

MacDonald v. The Queen, 2012 TCC 123, rev'd 2013 DTC 5091 [at 5982], 2013 FCA 110 -- summary under Subsection 84(2)

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. ...
TCC (summary)

Geransky v. The Queen, 2001 DTC 243 (TCC) -- summary under Subsection 84(2)

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). ...
TCC (summary)

GMAC Leaseco Corporation v. The Queen, 2015 DTC 1141 [at at 908], 2015 TCC 146 -- summary under Paragraph 12(1)(x)

The Queen, 2015 DTC 1141 [at at 908], 2015 TCC 146-- summary under Paragraph 12(1)(x) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x) amount subject to potential repayment obligation was not received General Motors of Canada Limited ("GMC") made "residual value support payments" to the taxpayer ("GMAC"), which purchased vehicles subject to leases, in consideration for GMAC increasing the residual values (thereby reducing lease payments). ...
TCC (summary)

Fourney v. The Queen, 2012 DTC 1019 [at at 2575], 2011 TCC 520 -- summary under Subsection 163(2)

The Queen, 2012 DTC 1019 [at at 2575], 2011 TCC 520-- summary under Subsection 163(2) Summary Under Tax Topics- Income Tax Act- Section 163- Subsection 163(2) line codes in electronic filings were incomprehensible to taxpayer Seeking to protect herself from being sued by her brother, the taxpayer transferred title to all her real properties for no consideration to corporations under her majority control. ...
TCC (summary)

Twomey v. The Queen, 2012 DTC 1255 [at at 3739], 2012 TCC 310 -- summary under Effective Date

A shareholders' resolution was passed "acknowledging the initial intent of the parties and issuing share certificates totaling 99 common shares of 115 to each of the Appellant and D.K. to correct the error without further consideration to be paid for them" (para. 9). ...
TCC (summary)

Twomey v. The Queen, 2012 DTC 1255 [at at 3739], 2012 TCC 310 -- summary under Qualified Small Business Corporation Share

A shareholders' resolution was passed "acknowledging the initial intent of the parties and issuing share certificates totaling 99 common shares of 115 to each of the Appellant and D.K. to correct the error without further consideration to be paid for them" (para. 9). ...
TCC (summary)

Guindon v. The Queen, 2012 TCC 287, rev'd infra -- summary under Subsection 163.2(4)

Various individuals (the "participants") supposedly acquired beneficial interests in an Ontario trust, which purportedly had been settled with time share units, in consideration for deferred payment obligations owing by them to the trustee, with the participants then "donating" their interests in the trust to the charity. ...
TCC (summary)

Aviva Canada Inc. formerly CGU Group Canada Ltd. v. The Queen, 2006 TCC 57 -- summary under Trademarks

The trademarks were acquired by NN Life on the same day as the sale to the appellant and NN Life gave consideration to Underwriters equivalent in value to what it received from the appellant. ...

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