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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.... ...

Now that MPP was an empty shell, Madison and Vanac transferred respective portfolios of rental properties to MPP in consideration for the assumption of liabilities and for the issuance of a mixture of Class B voting shares and Class C non-voting shares (with the same attributes other than being generally non-voting) so that Madison and Vanac collectively held (and in equal proportions, after giving effect to some catch-up transactions to equalize those holdings) 46.6% of the voting rights and 92.8% of the equity of MPP. ...

Corco purchased all of the appellant’s shares in consideration for issuing a $600,000 demand promissory note. ...

.$73 million (with the balance of the company sold two years later for US$63 million), the dominant shareholder of the company (James) engaged in estate freeze transactions and caused common shares representing 15% of all the common shares to be issued for nominal consideration to a trust for the benefit of present and future employees. ...

.$73 million, an estate freeze was implemented by its dominant individual shareholder, and a 15% common shareholding was issued for nominal consideration to a trust for the benefit of present and future employees. ...

This was accomplished by transferring their co-ownership interests on a s. 85(1) rollover basis to respective Newcos (“HP Newco”, in the case of Harvard Properties) in consideration inter alia for voting and non-voting shares, followed by a sale of those voting shares to an Abacus subsidiary (NH Properties) for promissory notes for under half of the sale price. ...

., transferred the shares of its subsidiary ("CAHL"), which was non-resident in Canada notwithstanding that it had been incorporated in Canada in 1929, to a newly incorporated Canadian-subsidiary of Products ("Holdings") in consideration for a common share of Holdings that had a paid-up capital equal to the fair market value of CAHL. ...