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., 2003 DTC 5078, 2003 FCA 22-- summary under Subsection 15(2) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2) Some of the shares held by the taxpayer in its French subsidiary were purchased for cancellation by the subsidiary in consideration for the assignment to the taxpayer of a note (denominated in French francs) owing to the subsidiary by a French partnership whose principal partner was the U.S. parent of the taxpayer. ...

., 2003 DTC 5078, 2003 FCA 22-- summary under Paragraph 212(13.1)(b) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(13.1)- Paragraph 212(13.1)(b) Some of the shares held by the taxpayer in its French subsidiary were purchased for cancellation by the subsidiary in consideration for the assignment to the taxpayer of a note (denominated in French-francs) owing to the subsidiary by a French partnership whose principal partner was the U.S. parent of the taxpayer. ...

We also wish to say that considering that subsection 171(2) of the Act is applicable and thus not a bar to the parties’ request, the fact that the parties are in agreement with respect to the manner in which their tax appeals should proceed, is a highly relevant, although not determinative, consideration in the exercise of the discretion to allow or not the parties’ request. ...

Canada, 2020 FCA 73-- summary under Subsection 168(7) Summary Under Tax Topics- Excise Tax Act- Section 168- Subsection 168(7) construction lien holdbacks excluded from taxable consideration Webb JA confirmed that a director who was assessed under ETA s. 323 for failure of the corporation to remit GST can challenge the correctness of the assessment of the corporation for the unpaid GST, even where it had failed to do so. ...

Canada, 2025 FCA 20-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) Deans Knight applied to corporate restart plan Under a “restart” plan, the appellant changed its name, spun out its existing mining assets so that it was a shell with only tax losses, and B.C. real estate companies of two individuals (Grippo and Heung) transferred various real estate assets, including jointly owned properties, to the appellant for consideration that included shares of the appellant. ...

In finding that the insurance charges made by it represented consideration for a taxable resupply, Malone JA stated: [I]t was the right to the protection offered by the fleet policies which constituted a taxable supply of service under the provision of section 123. ...

Larsen, 99 DTC 5757 (FCA)-- summary under Paragraph (a) Summary Under Tax Topics- Income Tax Act- Section 110.6- Subsection 110.6(1)- Qualified Farm or Fishing Property- Paragraph (a) timber was an incorporeal hereditament in land and, thus, real property The taxpayer and his three siblings gave a lumber company the right to enter their land to remove timber during a five-month period for consideration of $70 per cubic metre of timber removed. ...

" Stratas J.A. stated (at para. 9) that "nowhere does subsection 220(3.1) mention the year of assessment as a relevant consideration." ...

Noël J.A. stated at para. 33 that s. 10(1), which requires that inventory be valued at the lesser of cost or fair market value, overrides any GAAP considerations. ...

Noël J.A. stated at para. 33 that s. 10(1), which requires that inventory be valued at the lesser of cost or fair market value, overrides any GAAP considerations. ...