Search - consideration

The definition of a capital beneficiary included individuals (subject to specified exclusions) had made written application to the Trustee for consideration for inclusion as a Capital Beneficiary, had made charitable donations to one or more registered charities in the calendar year of such application and received receipts in prescribed form for such donations. ...

The next day, the taxpayer sold these shares to a partnership of which his wife was a general partner and three of his children held a 99% limited partnership interest in consideration for a $487,000 promissory note of the partnership bearing interest at the rate prescribed for purposes of s. 74.5. ...

-resident corporative association of dairy companies, received a fee from a Canadian member that was, in part, a royalty for the use in Canada of a certification mark and, in part, consideration for know-how provided by it to the Canadian member, namely, providing assistance on production, quality control, advertising and marketing. ...

Repairs or Running Expense perimeter road construction for promotion A large lump sum payment was made by the taxpayer to the City of Calgary in consideration of (i) the City improving the system of roads around the taxpayer's shopping centre and (ii) an implied promise of the City not to assess the taxpayer for local improvement taxes in respect of the cost of such improvements. ...

In consideration, the advertiser was to pay the newspaper's advertising fees in each month that those fees arose, and at the end of the twelve-month period to pay $1000 minus all the advertising fees spent in that period (or nothing at all if the fees exceeded $1000). ...

. … The words of the Act require consideration of a transaction in its entirety and it is not open to the Crown artificially to split off various aspects of it in order to create an avoidance transaction. ...

The Queen, 99 DTC 150, [1999] 1 CTC 2498 (TCC)-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) The taxpayer gifted a portion of his common shares of a family small business corporation to a trust for his children utilizing the rollover provisions of former s. 73(5) and then, approximately one month later, repurchased the shares in consideration for an interest-bearing promissory note. ...

., 97 DTC 5252, [1997] 2 CTC 286 (FCA)-- summary under Subsection 85(1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1) retroactive validation by Superior Court of preference share issuance was effective for s. 85 purposes The taxpayers agreed with the corporation controlled by them to transfer an apartment building to the corporation in consideration for the issuance of preference shares. ...

It was appropriate to allocate 25% of the fees paid to the casino operator as consideration for the exempt cheque-cashing service, and to treat the balance as taxable. ...

., purchased all the shares of Greenleaf from Ford U.S. for consideration of $1, and purchased the debt at only a slight discount to the amount owing, so that the debt-parking rules in ss. 80.01(6) to (8) did not apply. ...