Search - consideration

The reason for the mistake is simply not a consideration in the application of the section. ...

CRA originally denied input tax credit claims of CFI for the HST that was charged to it by the originators on the prepaid rent payments on the grounds that such payments were consideration for a financial service but, after some time, ultimately reversed that position and confirmed the ITC denials on the basis that CFI had not satisfied the documentary requirements of s. 169(4) and the Input Tax Credit Information (GST/HST) Regulations (the “Regulations”). ...

He assigned the other ½ of his shares to her in consideration for a promissory note of approximately $1M, and elected out of the application of s. 73(1), so that he realized a capital gain of approximately $1M and her ACB increased by this amount. ...

He went on to indicate (at para. 55) that, to determine the character of the single supply, it was necessary to determine “which element caused the payment of the consideration,” and then stated (at para. 57) that in light of the importance of the professional services provided by Dr. ...

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. ...

In order for two companies (“Madison” and “Vanac,” which dealt with each other and MPP at arm’s length) to access those losses and shelter gains and income from portfolios of rental properties, transactions were implemented, beginning in October 1997 which, in general outline, included the following: The common shares of the existing shareholders were exchanged for preferred shares and Class B voting common shares; Through a series of transactions, those shareholders’ preferred shares were effectively replaced by shares of a subsidiary of MPP to which it had transferred its mining assets (with that subsidiary then being amalgamated with third-party mining company), so that MPP was now an empty shell; and 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. ...

In addition, there is a geographical consideration in that the Foreign Interchange Service was provided to a non-resident merchant acquirer while expenses to redeem the points are incurred by RBC in Canada. … [E]xpenses incurred by RBC in the redemption of loyalty reward points were inextricably linked and an integral component of the Appellant’s agreement to extend credit pursuant to the Cardholder Agreement. ...

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. ...

GPDI would charge the merchant a merchant discount fee of, say, 2%, and pay CIBC an interchange fee of, say, 1.5% in consideration for CIBC’s authorization and payment services. ...