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Klink then transferred the computer to a recently-formed British Columbia limited partnership in consideration for a partnership interest therein. ...

Klink then transferred the computer to a recently-formed British Columbia limited partnership in consideration for a partnership interest therein. ...

The Queen, 97 DTC 1328 (TCC)-- summary under Safe-Income Determination Time Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(1)- Safe-Income Determination Time subsequent redemption of preferred shares was not assimilated to the series in which they were issued one or more year previously, given different objectives for each and lack of interdependence On September 10, 1988, the taxpayer transferred its assets to a subsidiary ("Alimentation 1988") in consideration for a demand promissory note and 506,125 Class B shares having a redemption value of $1 per share and nominal paid-up capital. 151,125 of the Class B shares were redeemed in the fiscal years of Alimentation 1988 ending on May 31, 1990, 1991 and 1992. ...

Klink then transferred the computer to a recently-formed British Columbia limited partnership in consideration for a partnership interest therein. ...

Klink then transferred the computer to a recently-formed British Columbia limited partnership in consideration for a partnership interest therein. ...

United Aircraft Corp. (1943), 7 A.T.D. 318 (HC)-- summary under Subparagraph 115(1)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 115- Subsection 115(1)- Paragraph 115(1)(a)- Subparagraph 115(1)(a)(ii) provision of knowhow in the US to Australian company not carrying on business in Australia An American manufacturer of airplanes purported to license its rights to use Australian patents and registered designs to an Australian company in consideration for a lump sum of $25,000 and further sums based on the number of aircraft engines manufactured by the Australian licensee. ...

., the taxpayer disposed of "a right to a right" of the sort described in what then was s. 66(15)(c)(ii)(B) when under a "farmout agreement" with Esso Resources Canada Limited, the taxpayer received from Esso the sum of $4.5 million in consideration for "... the right, licence and privilege of earning an interest in oil sands rights... ...

., that gifts could be made even where consideration was received, and that “Parliament did not intend for section 118.1…to produce radically different results for taxpayers in Québec that would not apply to taxpayers in the rest of Canada.” ...

. … The CRA invites the court to infer that there was no consideration of the legal issues by reason of the fact that Mr. ...

Richards in consideration for Ms. Richards’s guarantee – and as not resulting in any interest in the condo also being supplied by the builder to Ms. ...