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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. ...

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. ...