Search - consideration

(theretofore, a wholly-owned subsidiary, and a successor by amalgamation to UNAC and the U.S. parent of UNAC, and holding Univar Canada) to (newly-incorporated) UHI for notes and common shares of UHI, UHI transferred those Univar Inc. shares to (newly-incorporated) UHC for notes and common shares of UHC, and Univar NV transferred its remaining shares of Univar Inc. to UHC for a note which then was assumed by UHI in consideration for issuing common shares. ...

Similarly, respecting the divestiture-related fees of Lazard Frères incurred up to board approval of a butterfly spin-off, these related to advice and approaches to potential third-party purchasers of the shares through which the laminated products business was held as well as to the ultimate sale (on a rollover basis) of the shares of that laminated products company to Novelis in consideration for the acquisition of (subsequently redeemed) preferred shares of Novelis, and the calculation of the Lazard Frères success fee did not represent a percentage of the value of those shares – so that those fees also were deductible under s. 20(1)(bb) as well as under s. 9. ...

In concluding instead (at para. 145) that “income taxes at the shareholder level should not be taken into consideration in the determination of the fair market value of the shares of Holdco,” Lafleur J stated (at para. 150): [T]here is no reason to believe that Holdco will be liquidated in the near future. ...

Finally, he stated (at para. 436): [T]he fact that the reasonably expected gross income is expected to be realized on December 31, 2028 is not a consideration raised by paragraph 20(1)(c) of the ITA. ...

The Queen, 2018 TCC 102, aff'd 2020 FCA 115-- summary under Subsection 97(2) Summary Under Tax Topics- Income Tax Act- Section 97- Subsection 97(2) the starting ACB of a partnership interest was determined exclusively under s. 97(2)(b)/ no requirement to issue units In 2003 and 2004, the taxpayer (“Iberville”) contributed shopping centres worth $130M and with a cost base of $14M and received non‑share consideration or boot of $8.5M. ...

Colitto for nominal consideration. In 2016, the Minister assessed Ms. ...

Respecting 2010. after quoting with approval (at para. 17) the statement in Ivan Cassell that the applicable test under the PSB test was “whether, taking into consideration all the circumstances, [the specified shareholder] would reasonably be regarded as carrying on a business on his own account if [his personal corporation] did not exist,” Visser J stated (at paras. 27-28): Ms. ...

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. ...

In rejecting the taxpayers’ submissions that “all circumstances, including personal family circumstances and personal estate planning goals must be considered” (para. 90) and that the income and loss allocation methodology could be supported from the standpoint of estate planning objectives, he stated (at paras. 94, 97): [T]he reasonable business person would only consider factors relevant to their own business considerations having regard to their own business interest. ...

Singh for nominal consideration of two dollars, at a time that Mr. Singh’s tax debt was still owing. ...