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Concerning the intention of Ronald or Soutar Décor as to timing, actions or effect, section 160 is clear: intention is of no import beyond gauging the adequacy of consideration: Wannan v. ...

Turgeon) agreed to sell some preferred shares of the CCPC to a newly formed Holdco of its controller (“Hélie Holdco”) in consideration for a promissory note bearing interest at 4% and which was to be repaid over a number of years out of dividends or redemption proceeds received by Hélie Holdco from the CCPC. ...

In rejecting the Crown’s argument that the test in s. 104(2)(b) (of the multiple trusts being “conditioned so that the income thereof accrues or will ultimately accrue to the same beneficiary or group or class of beneficiaries”) must be applied on an annual basis, he stated (at paras 14, 15, 16 and 21): …[T]he text of paragraph 104(2)(b) appears to contemplate a consideration of the right to receive the income of the trust over the entire lifetime of the trust rather than for each taxation year. ...

. … Bocock J concluded (at para 40): Mayling remained the purchaser until closing and, as such, obligated to pay the consideration. … Therefore both the ETA and APS required the Appellant to collect and remit the HST. ...

Gendron") in consideration for a promissory note (payable in five annual instalments) and elected that s. 73 not apply to produce rollover treatment. ...

The Queen, 2014 TCC 156-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) stock-dividend value shift failed notwithstanding offsetting-gain to be realized on death; no basis adjustment requested The taxpayer, who had realized a capital gain of $30 million earlier in the year, subscribed for Class A common shares of a corporation newly incorporated by him ("Immeubles Molibec") in consideration for a demand promissory note of $22.5 million. ...

In finding that the IRCs did not qualify as coupons, Lamare ACJ stated (at paras. 29, 30, 31): The FCA, in Tele‑Mobile, made it clear that there cannot be a coupon unless something is submitted by the purchaser for acceptance as full or partial consideration for the taxable supply, and the coupon thus tendered, whether physical or electronic, must entitle the purchaser to a reduction of the price equal to a fixed dollar amount specified on the physical or electronic device. ...

The solution adopted was for PWR to then transfer high basis assets to the Holdcos in consideration for preferred shares of the same class, so that the PUC of the preferred shares held by Mr. ...

The key considerations …are: …{H]is primary intention … to sell …at a profit as soon as a reasonable return …could be realized. ...

The Queen, 2017 TCC 98, aff'd 2018 CAF 209-- summary under Subsection 245(3) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(3) not every transaction had estate-freezing objective Prior to the sale of a corporation ("Groupe AST") to a third party, its individual shareholder rolled his shares of Groupe AST into a holding company (“276”), and then the adjusted cost base of the shares of Groupe AST was stepped up to fair market value through a combination of Groupe AST increasing the stated capital of its shares, thereby generating a s. 84(1) deemed dividend to the taxpayer which was reported by it as a capital gain, and of 276 transferring the Groupe AST shares on a non-rollover basis to a subsidiary (“9144”) in consideration for Class A common shares with a high ACB. ...