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JS then transferred his shares of PC to a newly-incorporated holding company ("601") in consideration for a promissory note of 601 in the same amount and for the issue of common shares. ...

The Trial Judge had incorrectly found that the taxpayer had not made the payment referred to in (2) above, and the matter was referred back to the Minister for reconsideration of the third and fourth points above, together with consideration as to whether the claim by the taxpayer in his return for a business investment loss represented an election under s. 50(1). ...

After his common shares of Realwest had declined in value to $1,000, he (along with other investors in Realwest) transferred the shares of Realwest to a holding company in consideration for non-voting common shares of the holding company, thereby realizing an allowable business investment loss. ...

The Queen, 2001 DTC 243 (TCC)-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) The taxpayer, who owned a portion of the shares of the holding company ("GH") which, in turn, owned an operating company ("GBC") utilized the enhanced capital gains exemption in connection with the sale of a cement plant operated by GBC through the following transactions: the taxpayer and the other shareholders of GH transferred a portion of their shares of GH to a newly-incorporated company ("Newco") in consideration for shares of Newco having a value of $500,000; GBC paid a dividend-in-kind of most of the cement plant assets (having a value of $1 million) to GH; GH redeemed the common shares held in its capital by Newco by transferring to Newco the assets it had received from GBC; and the shareholders of Newco's sold their interests in Newco to the purchaser (who also purchased the remaining cement-plant assets directly from GBC). ...

Expense- Restrictive Covenants purpose of inducement for 5-year agency agreement was increasing sales The taxpayer, along with other oil companies, paid lump sums to service station owners in consideration for the owners' agreement to deal exclusively with the oil companies for a fixed number of years (generally, five years, but ranging up to 20 years). ...

The Queen, 2013 DTC 1018 [at at 93], 2012 TCC 406, rev'd supra-- summary under Total Charitable Gifts Summary Under Tax Topics- Income Tax Act- Section 118.1- Subsection 118.1(1)- Total Charitable Gifts The taxpayer purchased timeshare units for cash (as to 1/9 of the consideration) and promissory notes (as to the balance), and then donated the units (which had a fair market value equal only to the cash portion of the "donation") to a registered charity. ...

Davies J stated (at para. 143): [T]he CRA and MNR effectively approbated and reprobated the same conduct by the Appellant and thereby reached inconsistent decisions by failing to apply the same considerations and deemed facts to both applications. ...

The Queen, 2015 DTC 1141 [at at 908], 2015 TCC 146-- summary under Timing Summary Under Tax Topics- Income Tax Act- Section 9- Timing inducement payments received by lessor from manufacturer not income until potential repayment obligation quantified General Motors of Canada Limited ("GMC") made "residual value support payments" to the taxpayer ("GMAC"), which purchased vehicles subject to leases, in consideration for GMAC increasing the residual values (thereby reducing lease payments). ...

Bisson, 72 DTC 6374 (FCTD)-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) The taxpayer, who was the general manager and one of the two principal shareholders of a bus company ("Hull City Transport") agreed, in settlement of a dispute with the other principal shareholder ("Thorn"), to purchase the beneficial ownership of the shares of Thorn in consideration for annual payments of $3,000 for four years, and $5,000 per year thereafter until the sum of $60,000 had been fully paid. ...

The Queen, 86 DTC 6264, [1986] 1 CTC 507 (FCTD), aff'd 88 DTC 6522, [1988] 2 CTC 365 (FCA)-- summary under Paragraph 251(1)(c) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) JV company at arm's length with 50% shareholder Since the taxpayer was held to be dealing at arm's length with a corporation ("Clarebeau") 1/2 of whose shares were owned by the taxpayer's family holding company and 1/2 of whose shares were owned by the family holding company of his business associate ("Claridge"), a sale by the taxpayer of share purchase options to Clarebeau for nominal consideration was governed by s. 7(1)(b) rather than s. 7(1)(c). ...