Search - consideration

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. ...

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. ...