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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. ...

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. ...

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 (a.k.a., resort points) to the Vacation Homes to them in perpetuity. ...

The solution was for PWR to then transfer high basis assets to the Holdcos in consideration for preferred shares of the same class, so that the PUC of the preferred shares held by Mr. ...

Canada, 2019 FCA 57-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) interest by its nature is symmetrical As part of a complex set of transactions, a predecessor of the taxpayer agreed to assume a $225M loan that was due in perhaps 43-years’ time and that was non-interest-bearing (except in the remote event of oil production from the Beaufort Sea) in consideration inter alia for the payment to it of $17.5 million by the debtor. ...

Canada, 2019 FCA 147-- summary under Ordinary Meaning Summary Under Tax Topics- Statutory Interpretation- Ordinary Meaning ambiguity can arise on consideration of how the provision interacts with another Noël C.J. went on to find, on a purposive interpretation of ETA ss. 132(3) and 150(1) that, notwithstanding that an ETA s. 150(1) election made between the two companies was deemed by s. 150(1) to cause “every supply” between them to be an exempt financial supply, administrative services supplied by the appellant to the non-resident permanent establishment of a resident affiliate with whom it had so elected instead were deemed to be zero-rated supplies. ...

Canada, 2019 FCA 306-- summary under Shares Summary Under Tax Topics- General Concepts- Fair Market Value- Shares FMV of shares reduced by accrued, but not yet payable, corporate income tax on gains An individual rolled his apartment building into a Newco in consideration for a mortgage assumption and shares with nominal paid-up capital, and then rolled those shares into a new Holdco. ...

In the context of negotiations that led to the sale of the shares of Public Mobile to Telus, Pangaea and a resident shareholder (“Thomvest”) entered into a letter agreement that provided that Thomvest would pay $3,000,000 as consideration for Pangaea’s agreement to execute a share purchase agreement. ...

. … The Tax Court Judge was not bound by any admission that CIBC was paying for Aeroplan Miles in light of the agreement, which was properly tendered as evidence at the Tax Court hearing, and which clearly states that the payments made by CIBC were in consideration of Aeroplan “referring or arranging for Aeroplan Members and other members of the public to make Card Applications”. ...

. … The Tax Court Judge was not bound by any admission that CIBC was paying for Aeroplan Miles in light of the agreement, which was properly tendered as evidence at the Tax Court hearing, and which clearly states that the payments made by CIBC were in consideration of Aeroplan “referring or arranging for Aeroplan Members and other members of the public to make Card Applications”. ...