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Immediately before the closing of the sale to MDPC, the taxpayer exchanged all his commons shares of MDPC under s. 86 for preferred shares with a redemption value of $2 million and for new common shares of MDPC, and then immediately sold 85% of those common shares equally to his wife and two children for nominal consideration. ...

In July 2013, the husband transferred his ½ co-ownership interest (the “Interest”), in a real estate property that they co-owned, to her for no stated consideration. ...

The Queen, 2018 TCC 113-- summary under Subpargraph 12(1)(x)(viii) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x)- Subpargraph 12(1)(x)(viii) an early signing bonus was part of the proceeds of disposition of the subject property The taxpayer, who rented his farm to a corporation controlled by him, received an early “signing bonus” of $255,790 from Enbridge for entering into an agreement with Enbridge by the stipulated deadline under which he granted an easement for a pipeline to Enbridge for additional stipulated consideration and damages. ...

He further quoted approvingly (at para. 13) the statement in Jones that “similar considerations should apply to recreational activities.” ...

After finding that a settlement agreement had been reached (given the parties’ mutual intention to create legal relations, the flowing of consideration, sufficiently clear terms, and a matching on all essential terms), Lyons J went on to note (at para. 62) that: University Hill … reaffirmed the principles in Galway and CIBC and commented that settling the quantum of expenses is not an all or nothing function and involved a compromise of facts, therefore, “the Court will only interfere if the agreed‑upon facts clearly have no bearing to reality.” ...

Colitto) for nominal consideration. In 2016, CRA assessed Ms. Colitto on the basis that Mr. ...

This last consideration regarding time spent in each location is very important and must be given great weight. … [T]he Appellant and her husband may retire approximately two years after the hearing of this matter. ...

In finding that such expenses did not qualify for deduction under s. 8(1)(b), Lafleur J stated (at para. 28, TaxInterpretations translation) respecting the first ground of his action noted above: [I]t did not seek to recover any amount that would have been due in consideration of Mr. ...

These transactions depended in part on the appellants being considered to have acquired units of an income fund ("FMO") from another income fund ("TOM") (which in turn had purportedly acquired the FMO units from an RRSP in consideration for issuing TOM units to it) at a cost equaling the units’ FMV, followed immediately by a distribution to them of capital gains that had been realized by FMO – with that distribution not reducing the ACB of their units by virtue of s. 53(2)(h)(i.1)(A) and (B)((I). ...

If paragraph (a) did not apply, it is my view that paragraph (b) of the definition of “recipient” would apply in the alternative because it is my view …the MacNaughtons were liable to pay the consideration for the purchase of the Tobacco Products.... ...