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The Queen, [1999] GSTC 119 (TCC)-- summary under Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Supply cancellation charges were consideration for a supply The registrant served retail travel agencies by booking and purchasing airline tickets for the agencies' customers, which resulted in the receipt by it of commissions from the airlines. ...

Before finding that this $15 charge was consideration for a financial service, Archambault J rejected (at para. 22) a submission of the registrant that it claimed payment from the credit card issuers as mandatary of the retail agencies: It was not established that Skylink had agreed with the retail agencies that it would act as their mandatary by requesting payment from the issuers. ...

.)-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose deductible lump-sum cancellation of profit participation payment The taxpayer, which provided management services to its two subsidiaries which, in turn, ran a cellular phone system and sold cellular telephones, agreed with an American cellular telephone company ("Millicom") to pay an annual fee equal to 10% of its consolidated pre-tax profits for 15 years in consideration for the supply to the taxpayer from time to time at its request with future know-how. ...

Expense- Contract or Option Cancellation The taxpayer made a lump-sum payment to terminate an agreement under which an American company agreed to supply the taxpayer from time to time at its request with future know-how in consideration for an annual fee equal to 10% of the taxpayer's consolidated pre-tax profits for 15 years. ...

The Queen, 2014 TCC 375-- summary under Evidence Summary Under Tax Topics- General Concepts- Evidence evidence of surrounding circumstances including income tax objective relevant to contract interpretation Before finding that the consideration for management services provided by a mutual fund trust manager to the trusts did not include special rebate distributions that the trusts were obligated to pay to large unitholders, and before finding (at paras. 72, 76) that the surrounding circumstances established that the parties intended to follow an ATR-65 structure, which required that the special distributions satisfy obligations of the trusts rather than the manager, Campbell J stated (at para. 45): [E]vidence respecting surrounding circumstances… will be limited to the objective evidence of the background facts at the time of formation and execution of the contract. … As noted in Sattva [2014 SCC 53], considering surrounding circumstances, as an interpretative aid, does not offend the parol evidence rule, which excludes evidence of the parties' subjective intentions and precludes considering evidence outside the words of the contract that would result in varying the contract in some manner. ...

Thereafter, all the consideration paid by Clearly Canadian for the services of the taxpayer was satisfied by the payment of fixed monthly amounts to the taxpayer pursuant to a "legal services agreement". ...

The concept of 'an economic activity' is an activity which typically is performed for a consideration and is connected with economic life in some way or another. ...

The distribution to the taxpayer was found to be part of the consideration for the contribution of property made by it to the partnership. ...

The Queen, 2000 DTC 6127 (FCTD)-- summary under Section 96 Summary Under Tax Topics- Income Tax Act- Section 96 A purported partnership ("Anwin") of which the taxpayer was a limited partner entered into a joint venture agreement with a corporation ("Anaquan") which was also the general partner of Anwin pursuant to which Anaquan agreed, in consideration for funding by Anwin, to incur qualifying research expenditures on the conduct of research at its facility in Winnipeg and to pay 10% of its gross income from the research facility, up to an annual maximum of 20% of the contract price, for the first five years of the agreement, and for the next five years to pay 5% of such gross income up to an annual maximum of 10%. ...

Although from CRA's perspective, what the casino was mostly getting paid for was its clerical services and the provision of the space, Sharlow JA found that the "commercial efficacy" of the whole arrangement turned on the provision of the cash by the casino, so that the fee was consideration for a single supply of a financial service under para. ...