Search - consideration

At month’s end, Elavon would collect the $2 merchant fee (2%) from the merchant’s bank account which was then distributed as follows: Elavon pays $1.50 (the interchange fee) to the card issuer and payment network; the remaining $0.50 cents (the “mark-up”) is the revenue shared between Elavon and Zomaron in accordance with a negotiated split – say, 30%/70%, so that Elavon retains $0.15 and pays Zomaron $0.35, representing its portion of the fee as consideration for its services. ...

The Queen, 2020 TCC 64, aff'd 2021 FCA 142-- summary under Subsection 152(6) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(6) a CRA policy to adjust loss carrybacks, to a reassessed year, beyond the s. 152(6) period, had no statutory authority The Minister assessed the taxpayer in 2010 under s. 160 respecting a transfer of $1 million in property made to it by an affiliate (“661”) for no consideration in 2003 at a time that CRA considered that 661 had an unpaid tax liability for 2000. ...

The $744,800 amount recognized as the consideration for Lockwood’s services “thus becomes the adjusted cost base of the AOI shares received in 2012. ...

He went on to indicate (at para. 55) that, to determine the character of the single supply, it was “necessary to identify all of the elements of the supply and then determine which element gave the supply its commercial efficacy, or in other words 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. ...

(“Abitibi”), having an FMV of $191.8 million and a nominal ACB, to 366 on a s. 85(1) rollover basis in exchange for preferred shares of 366. 366 then redeemed such preferred shares in consideration for issuing a note to Québecor, and repaid the note by transferring the Abitibi shares back to Québecor. ...

Consideration of the correctness of an assessment is within the exclusive jurisdiction of the Tax Court. … The Tax Court will address all challenges to the correctness of the assessment made after the transfer pricing provisions have been applied, including whether the conditions for their application are met, the amount of any adjustments, the liability for penalties and whether the Minister exercised her discretion properly. ...