Search - consideration

London Life acquired the construction inputs for the purpose of providing taxable supplies, i.e. leasehold improvements to its landlords for consideration, i.e. the tenant improvement allowances. ...

But when the leasing transactions are considered independently, London Life is supplying the leasehold improvements to the landlords for the consideration of the leasehold improvement allowances. ...

Although the value of the benefit which was received, rather than the cost of the benefit to the corporation was relevant test, "in determining the value of benefit, one may take its cost into consideration" (p. 6325). ...

When a vessel of the taxpayer ceased to be operational due to a need for major repairs, the taxpayer agreed with the charterer to cancel the charter party in consideration for the payment by the taxpayer of $130,203.44, thereby eliminating potential substantial claims by the charterer. ...

., 99 DTC 5772 (FCA)-- summary under Subsection 97(2) Summary Under Tax Topics- Income Tax Act- Section 97- Subsection 97(2) partnership not transparent re partnership borrowing to pay vendor partner The taxpayer transferred land to a partnership for consideration of $13.5 million which was satisfied by that amount being paid by the partnership, out of new partnership borrowings in excess of that amount, in order to discharge a mortgage owing by the taxpayer prior to the transfer on the transferred land. ...

The Queen, 2006 DTC 3006, 2006 TCC 256-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) The taxpayer transferred assets of a business to a partnership in what was intended to be an s. 97(2) rollover transactions in consideration for cash, promissory notes and assumption of debt ("boot") totalling an amount less than the cost amount of the transferred assets, and a Class "F" partnership interest stipulated to have a value equal to the balance of the purchase price. ...

He concluded (at para. 38) that "the system of submission of claims does not constitute an ‘invoice'…[and] the moment when the consideration for the taxable supply becomes due is the moment when the manufacturer approves the claim. ...

Thorn EMI plc, [1987] DTC 462 (CA)-- summary under Property Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Property A lump sum which the taxpayer (a British holding company) received as consideration for a non-competition agreement given by it to the U.S. purchaser of three operating companies indirectly owned by it was found to be a capital gain pursuant to s. 22(3) of the Finance Act 1965 which provided that: "There is... a disposal of assets by their owner where any capital sum is derived from assets notwithstanding that no asset is acquired by the person paying the capital sum.... ...

The Queen, 2004 DTC 2604, 2004 TCC 280, briefly aff'd 2006 DTC 6351, 2006 FCA 171-- summary under A Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Undepreciated Capital Cost- A A partnership acquired Canadian rights to software in consideration for $960,000 in cash and an acquisition note in the amount of $12.15 million under which the interest was capitalized for the first nine years and thereafter quarterly instalments became due. ...

MNR, 96 DTC 1094, [1996] 1 CTC 2218 (TCC)-- summary under Paragraph 18(1)(e) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(e) The taxpayer, which ran a funeral home business and agreed with many of its customers to provide the required funeral services on each customer's death in consideration for a lump sum paid by the customer at or shortly after entering into the contract, also entered into a contract with the Fiducie du Quebec (the "Trustee") under which it was agreed that the Trustee would credit all sums of money delivered to it into a capital account, and credit 40% of all income earned on the capital account and a reserve account into that reserve account. ...