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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). ...

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. ...

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). ...

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). ...

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. ...

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. ...

After finding that the registrant's $15 fees to the travel agencies qualified as consideration for services described under paras. ...

The Queen, 2001 DTC 345 (TCC), briefly aff'd 2002 DTC 7378, 2002 FCA 336-- summary under Paragraph 227(8)(a) Summary Under Tax Topics- Income Tax Act- Section 227- Subsection 227(8)- Paragraph 227(8)(a) due diligence defence not established in absence of evidence of professional advice Before finding that a due diligence defence had not been made out respecting the imposition of a 10% penalty under s. 227(8)(a) respecting failure to withold on consideration, paid to a non-resident company ("Marco"), which the taxpayer unsuccessfully argued was not for "services," and after noting (at para. 40) that a due diligence defence, based on Consolidated Canadian Contractors, was available if it could be made out on the facts, Lamarre J stated (at paras. 41-43): The issue then becomes one of whether the appellants can positively prove that all reasonable care was exercised to ensure that errors not be made (see Pillar Oilfield Projects Ltd. v. ...

The Minister considered that the Fund obligations to pay the Management Fee Distributions to the large investors was part of the consideration that the Funds provided in exchange for the appellant's services, and assessed the appellant for failure to charge GST on the gross amounts. ...

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