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., 97 DTC 5252, [1997] 2 CTC 286 (FCA)-- summary under Subsection 85(1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1) retroactive validation by Superior Court of preference share issuance was effective for s. 85 purposes The taxpayers agreed with the corporation controlled by them to transfer an apartment building to the corporation in consideration for the issuance of preference shares. ...

., 99 DTC 5494, [1999] 2 CTC 133 (FCA)-- summary under Subsection 122.3(1) Summary Under Tax Topics- Income Tax Act- Section 122.3- Subsection 122.3(1) provision of services by governement for fees was an undertaking and business The taxpayer was employed by the New Brunswick Department of Agriculture and Rural Development to assist in establishing and administering several dairy farms in Malawi, in consideration for which the Department received fees that were intended to cover its cost, cover overhead and make a small profit. ...

., a business The taxpayer was employed by the New Brunswick Department of Agriculture and Rural Development to assist in establishing and administering several dairy farms in Malawi, in consideration for which the Department received fees that were intended to cover its cost, cover overhead and make a small profit. ...

Berg, 2014 DTC 5028 [at at 6664], 2014 FCA 25, rev'g infra-- summary under Total Charitable Gifts Summary Under Tax Topics- Income Tax Act- Section 118.1- Subsection 118.1(1)- Total Charitable Gifts intent to be enriched from tax credits The taxpayer purchased timeshare units for cash equaling their fair market value and issued bogus promissory notes for nine times the units' fair market value as purported additional consideration for the units. ...

Although from CRA's perspective, what the casino was mostly getting paid for was its clerical services and the provision of the space, Sharlow JA found that the "commercial efficacy" of the whole arrangement turned on the provision of the cash by the casino, so that the fee was consideration for a single supply of a financial service under para. ...

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. ...

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. ...

., 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.” ...