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The failure to fix, at that time, the fair market value of the assets, and to prepare a schedule specifically listing them, represented a delay in dealing with purely "housekeeping measures"; and given that under Manitoba corporate law, a corporation had the capacity and the powers of a natural person, it was not germane that the purchasing corporation had not ratified the oral contract on that date (nor was it relevant that there was a significant delay before the consideration was paid). ...

An amount subsequently received by the taxpayer in consideration for his agreement to end his participation in this housing program was found to be a benefit from employment given that the housing program was offered as an incentive for relocation to the Fort McMurray plant, the program was offered only to employees of Syncrude Canada and, but for his continuing employment with Syncrude Canada, he never would have received the termination payment. ...

., 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. ...

The King, 2023 TCC 167-- summary under Subsection 215(6) Summary Under Tax Topics- Income Tax Act- Section 215- Subsection 215(6) CRA decisions to make “protective assessments” of the dividend recipients under s. 212(2) in addition to assessing the dividend payers under s. 215(6) was troubling under Galway Regarding the CRA decisions to not only assess the dividend payer under s. 215(6) but also make “protective assessments” of the dividend recipients under s. 212(2), Goyette JA stated (at para. 106): The Crown’s position is troubling as it seemingly contradicts the Minister’s statutory duty to assess and make decisions based on the facts and the law and to not make deals or take positions that are divorced from these considerations [citing inter alia Harris and Galway] …. ...