Search - consideration

It was appropriate to allocate 25% of the fees paid to the casino operator as consideration for the exempt cheque-cashing service, and to treat the balance as taxable. ...

Requested documents included GAAR Committee minutes including comments of individual members (whereas CRA had provided only the final Recommendation of the Committee), and correspondence between CRA and Finance (resulting in the drafting of s. 256(7)(c.1))and between the GAAR Committee and Aggressive Tax Planning, with the questions seeking particulars on the questions posed above and policy considerations brought to bear on this file, and respecting what initially may have been diffidence on the part of Finance as to how to proceed, if at all. ...

After noting (at para. 44) that adapting the traditional jurisprudential test of employment to the PSB contest was a “simple matter” of “asking whether, taking into consideration all the circumstances, Mr. ...

Developer, respectively”) transferred individual resort condos (the “Vacation Homes,” which they had acquired in Canada, the U.S. and Mexico) to the Appellant (which was a non-share corporation resident in Canada) in consideration for the Appellant transferring occupancy rights to the Vacation Homes, in perpetuity to them. ...

Smith J also found that the exemption clause in the will had no effect, and concluded (at paras 44 and 45): I find that the overall evidence clearly establishes that she received property following a transfer of the residence without consideration from her brother, and that the four criteria set out in Livingston … have been met. ...

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

The taxpayer 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. ...

On December 7, 2007, the Limited Partnership transferred beneficial ownership of the rights to the pending permits (the “Purchased Applications and Purchased Permits”) to Devonian (while retaining legal title in trust for Devonian until the permits were granted) in consideration for Devonian agreeing to issue 999 shares. ...

As one of the steps that was necessary in order to secure approval and implementation of the Plan of Arrangement, Amoco assumed the obligations of Encor under the exploration loan in consideration inter alia for Encor paying Amoco $17.5 million and agreeing to vote in favour of the Plan of Arrangement and to cooperate with Amoco in the renegotiation of the loan with APCJ. ...

" The taxpayers submitted in the alternative that they were entitled to a charitable donation tax credit for the cash portion of their donations, submitting (at para. 80) that “the theory that consideration vitiates a gift is not based on the common law but is, rather, a recent innovation of revenue officials.” ...