Search - consideration

., 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. ...

., 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. ...

Bueti, who was entitled to receive 1/3 of the residue of estate of her father (who died in August 1999), was found to have purchased, as joint tenant with her husband, a property (a house) included in her father estate for consideration of $50,000, which was less than its fair market value at the time of the July 2000 purchase. ...

Applied to the subject under consideration the result is as follows. Insofar as the Explanatory Notes cast light on the objective setting or contextual scene of the statute, and the mischief at which it is aimed, such materials are therefore always admissible aids to construction. ...

The Tribunal accepted the characterization of the taxpayer's accounting expert, which was that the Lender had made the loan in consideration for the right to receive back the principal plus the right to require a transfer of value between its wholly-owned subsidiaries, which latter right was of no incremental value to it, so that there should be no corresponding recognition of accounting income. ...

The consideration paid by Ontra-Desar was stated to include the discharge by it of the second mortgage liability of Clearstream to the taxpayer including the arrears interest. ...

The Queen, 2015 TCC 191 (Informal Procedure)-- summary under Tax Shelter Summary Under Tax Topics- Income Tax Act- Section 237.1- Subsection 237.1(1)- Tax Shelter shelter based on potential interests rather than what actually was acquired The taxpayers entered an arrangement with a corporation ("Blue Hill") in order to deduct Canadian resource expenditures from income: the taxpayers paid $2 for an option to acquire an interest in mineral claims owned by Blue Hill; in exercising the options, the taxpayers agreed to engage Blue Hill to incur CRE on their behalf in consideration for promissory notes Lyons J found (at para. 42) that the taxpayers were not required by Blue Hill to pay the promissory notes. ...

., 99 DTC 5494, [1999] 2 CTC 133 (FCA)-- summary under Subsection 122.3(1) Summary Under Tax Topics- Income Tax Act- Section 122.3- Subsection 122.3(1) provision of services by governement for fees was an undertaking and business The taxpayer was employed by the New Brunswick Department of Agriculture and Rural Development to assist in establishing and administering several dairy farms in Malawi, in consideration for which the Department received fees that were intended to cover its cost, cover overhead and make a small profit. ...

., a business The taxpayer was employed by the New Brunswick Department of Agriculture and Rural Development to assist in establishing and administering several dairy farms in Malawi, in consideration for which the Department received fees that were intended to cover its cost, cover overhead and make a small profit. ...

Berg, 2014 DTC 5028 [at at 6664], 2014 FCA 25, rev'g infra-- summary under Total Charitable Gifts Summary Under Tax Topics- Income Tax Act- Section 118.1- Subsection 118.1(1)- Total Charitable Gifts intent to be enriched from tax credits The taxpayer purchased timeshare units for cash equaling their fair market value and issued bogus promissory notes for nine times the units' fair market value as purported additional consideration for the units. ...