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Hershfield J found that the amended purchase agreement entailed, at most, a supply of a co-ownership interest in the property by the appellant to her friend in consideration for her friend’s guarantee – and did not result in any interest in the condo also being supplied by the builder to the friend (so that the new housing rebate was not denied to the appellant). ...

Additionally, this Court found that where subsection 165(3) is in play, potential concerns with respect to the timeliness of the Minister’s consideration of a notice of objection can be addressed by the exercise of the appeal right that is available to the taxpayer on the 91st day after the filing of the notice of objection. ...

She was given no consideration for the funds. At the time, the appellant was aware that the taxpayer was having “issues” with CRA; the taxpayer had worked as an independent contractor and had failed to pay any tax from his business and had failed to file tax returns for several years. ...

Simard-Beaudry, 71 DTC 5511 (FCTD)-- summary under Tax debt Summary Under Tax Topics- Income Tax Act- Section 222- Subsection 222(1)- Tax debt liability for tax arose before assessment The taxpayer agreed in Montreal on December 15, 1964 to acquire assets of another company for consideration which included the assumption of all corporate income taxes which had been incurred prior to January 1, 1965. ...

Developer, respectively”) transferred individual resort condos (the “Vacation Homes,” which they had acquired in Canada, the U.S. and Mexico) to the Appellant (which was a non-share corporation resident in Canada) in consideration for the Appellant transferring occupancy rights to the Vacation Homes, in perpetuity to them. ...

Of the sums collected, 40% were retained by it as the agreed consideration for its services, and the balance of 60% was paid to the physicians – except that the clinic deducted from this payment to an amount calculated as 7% GST on the (40%) value of its services. ...

Among other considerations, after October 1, 2010, anyone in Quebec wishing to issue an insurance product was required to hold an insurer's licence. ...

The Queen, 2016 TCC 17-- summary under Subsection 136(1) Summary Under Tax Topics- Excise Tax Act- Section 136- Subsection 136(1) s. 136 applied to agreement to offer, at a distant date, to license sports complex to unidentified individuals Tardif J found that two agreements under which Quebec City agreed to pay a $10M grant to Laval University for the expansion of its sports complex and the University agreed that the City populace would have access to the complex for 70% of its operating hours constituted a supply by the University in consideration for the $10M. ...

The Queen, 2016 TCC 17-- summary under Section 2 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule V- Part VI- Section 2 agreement to licence sports complex in futre to City inhabitants was a real property supply Tardif J found that two agreements under which Quebec City agreed to pay a $10M grant to Laval University for the expansion of its sports complex and the University agreed that the City populace would have access to the complex for 70% of its operating hours constituted a supply by the University in consideration for the $10M. ...

In reversing this decision, Smith J stated (at p. 492): To so construe [s. 87] is to put a narrow and technical construction upon the precise words used in clause (d), without taking into consideration the meaning and intent of the statute as a whole. ...