Search - consideration

A court should give significant consideration to amendments which further the ability of the trial court to determine the questions in controversy …. ...

The consideration paid included a promissory note for $190,000 with a five-year term and bearing interest at 7.5%. ...

The Queen, 2022 TCC 13-- summary under Subsection 104(6) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(6) s. 104(6) permitted the deduction of an amount initially treated as a capital distribution An estate engaged in accelerated pipeline transactions in which it transferred shares (stepped up under s. 70(5)) of a portfolio company (“Holdco”) to a Newco in consideration for a note, with Holdco being wound up into Newco a day later – and with the note being repaid by Newco to the estate about three weeks later. ...

The reason for the mistake is simply not a consideration in the application of the section. ...

This reporting was accepted by the Court of Quebec on the basis inter alia that the equivalent of ITA s. 7(3)(a) established that the stock option rules constituted a “complete code” so that the equivalent to ITA s. 69(1)(b) did not apply to deem the “value of the consideration for the disposition” received by the taxpayer to be equal to the options’ fair market value of $3M, rather than the nil proceeds in fact received. ...

The King, 2023 TCC 67 (Informal Procedure)-- summary under Recipient Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Recipient the recipients of a supply were the agents named in the purchase agreement, not the beneficial purchaser A claimant of the new residential rental property rebate (NRRPR) is required under s. 256.2(3)(a) to be the “recipient” of the supply of the property meaning, generally, that it is liable for the consideration for the supply under the purchase agreement. ...

Lanery, were employee remuneration for CPP and EI purposes turned on a determination of their “dominant purpose,” namely, “whether on balance the payments were made on account of monetary assistance to enhance the PDF’s education and research skills or paid as income in consideration of various services provided by the PDF to the University.” ...

Lanery) were employee remuneration for CPP and EI purposes turned on a determination of their “dominant purpose,” namely, “whether on balance the payments were made on account of monetary assistance to enhance the PDF’s education and research skills or paid as income in consideration of various services provided by the PDF to the University.” ...

Spiro J referred to the taxpayer’s experience in the real estate area, and stated (at para. 79): The Appellant knew or ought to have known that acquiring more than $2.4 million of corporate property from HGSL for no consideration was a shareholder benefit. ...

As soon as LBL delivered the products to the store vicinity, and it received the cash consideration, the products were loaded onto the waiting trucks of customers, in turn, of Roberta MacNaughton. ...