Search - consideration

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. ...

The King, 2023 TCC 45, aff'd 2025 FCA 27-- summary under Specified Provincial Input Tax Credit Summary Under Tax Topics- Excise Tax Act- Section 236.01- Subsection 236.01(1)- Specified Provincial Input Tax Credit Bell Canada received single supplies of electricity from its Ontario electricity suppliers so that their full charges were subject to provincial ITC recapture The appellant (Bell Canada) was required as a result of ETA s. 236.01 and Part 6 of the New Harmonized Value-added Tax System Regulations, No. 2 (the “Recapture Regulations”) to recapture 100% of the input tax credits that it claimed in respect of the 8% tax that it paid under s. 165(2) on the consideration for the supplies to it in Ontario of electricity. ...

The Queen, 2017 TCC 212 (Informal Procedure)-- summary under Substantial Renovation Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Substantial Renovation gutting only half the rooms in a house did not qualify The taxpayer appealed a decision of the Minister to reject his claim for a GST new housing rebate on the basis that the building “looked like new”, the CRA’s analysis was flawed, and that drywall should be excluded from consideration. ...

In rejecting the Crown's position that such 20% share was taxable consideration for administrative, billing and marketing services supplied to the sleep physicians by MedSleep, Bodie J found that: The fee-sharing agreements were valid for tax purposes notwithstanding that, under provincial health care law, payments for physicians’ services could be made by the provincial health insurance plans to physicians only; and The fee-sharing agreements did not contemplate that MedSleep would provide the alleged admin and marketing services to the sleep physicians and they instead indicated that MedSleep was entitled to a portion of the professional fees generated from medical services provided to the patients. ...

Souty and Virtuose selling special voting shares of W4N to EMC Canada for nominal consideration so as to effect an acquisition of control of W4N and a resulting year end. The balance of the shares of W4N now being sold directly, or through a sale of the balance of the Virtuose shares, for cash consideration of over $15 million, such that Souty Holdco and Virtuose reported capital gains of around $4.7 million each (reflecting a reduction for the ACB bump in step 1), and modest capital gains were reported by Souty and Foix on the sale of their respective shares for about $0.8 million each (having regard to their purported s. 110.6 ACB step-up in step 2 to $0.75 million). ...

Approximately half way through construction, the Province decided that there would not be a new university, the agreements were terminated, and (after negotiations) a settlement agreement was entered into among the five parties in which Tech BC agreed on behalf of itself and the Province to pay $41.1M to ICBC in consideration for ICBC, IPL and Mall Co releasing Tech BC and the Province from all obligations under the project agreements. ...