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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.” ...

The Queen, 2018 TCC 182, rev'd on s. 95(1)- investment business- (a) (arm's length conduct) grounds 2020 FCA 79, in turn aff'd 2021 SCC 51-- summary under Paragraph (a) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(1)- Investment Business- Paragraph (a) Barbados-licensed international bank, which used Loblaw funding to invest responsively to Loblaw considerations, conducted an offside non-arm’s length business The taxpayer, which was an indirect wholly-owned subsidiary of Loblaw Companies Limited (a Canadian public company) wholly-owned a Barbados subsidiary (GBL), that was licensed in Barbados as an international bank, and (as was relevant under s. 95(2)(l)((iv)(C)) also wholly-owned a Schedule I bank. ...

In finding that the premiums received by Applewood qualified for exemption as consideration for the arranging for the issuance of financial instruments (paras. ...

. … (1) they did not refer to prior sales of the property; (2) there is no reference to providence; (3) there was multiples of the same print bought and dated; (4) there was no reference to the price paid by the donors; (5) the use of the art was not considered; and (6) no consideration was given to the impact of the flooded market place. ...

The “contextualist” approach, on the other hand, allows for the consideration of extrinsic evidence when there is latent ambiguity, thus making it possible for the factual matrix surrounding the contract at the time it was formed to be considered. ...

Rossiter CJ also found that there was an exchange of legal consideration, stating (at para. 132): Black’s direct advancement of funds to International on Inc.’s behalf is not a bar to a loan existing between Black and Inc. ...