Search - consideration

The taxpayers acquired such FMO units from TOM in consideration for issuing $161M in promissory notes. ... The units of FMO were repurchased by FMO for nominal consideration. The appellants had full (FMV) cost for their FMO units when acquired in steps 2 and 4, and the capital gains distribution in step 6 did not reduce the ACB of their units by virtue of s. 53(2)(h)(i.1)(A) and (B)(I). ...

It was held that s. 6(3)(e) did not apply because at the time of entering into the second contract the hospital already owed him (and admitted owing him) $30,000, and the $30,000 accordingly should not be regarded as consideration for his covenant. ...

An analysis which excludes consideration of events and evidence arising after the funds had been put to their original use, would severely limit the exceptional circumstances inquiry. ...

In order for an expenditure to be deductible as an "expense" under s. 20(i)(e)(ii) it must not give rise to an asset (such as the benefit of even temporary insurance) and it must have no consideration other than obtaining the loan. ...

The taxpayer then reacquired the property, with a view to reselling it, for consideration that included the extinguishment of Soni's payment obligation to it. ...

"Such agreement was part of the inducement or consideration for the transfer of his shares by Beaupré to the respondent. ...

The Queen, 79 DTC 5186, [1979] CTC 262 (FCA)-- summary under Subsection 212(5) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(5) The non-resident taxpayer, which had acquired from another film distributor the exclusive right for a limited period of time to show certain films on the CBC French-language network, agreed in consideration for a lump-sum payment to supply copies of those films to the CBC and to grant it for the same period of time the exclusive right to show them on its television network. ...

Kieboom, 92 DTC 6382, [1992] 2 CTC 59 (FCA)-- summary under Subsection 74.1(1) Summary Under Tax Topics- Income Tax Act- Section 74.1- Subsection 74.1(1) In finding that s. 74(1) applied to attribute dividend income to the taxpayer when he permitted his wife to subscribe for common shares of his private company for nominal consideration, Linden J.A. stated (p. 6386): "In my view, the phrase 'transfer of property' is used in this provision in a rather broad sense... ...

Denton"), who was entitled to a cash legacy of $90,000, purchased accounts receivable of $483,350 owing to the estate in consideration of (1) her releasing the estate from its liability to pay her $90,000 and (2) her paying $380,000 to the estate. ...

., 2003 DTC 5027, 2002 FCA 520-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) no evident policy against debt parking In order to avoid the application of the pre-1994 version of section 80, debt owing by the taxpayer was sold by a bank (for consideration equal to 2.2% of the total amount owing) to a corporation ("W720") that had similar ownership to the taxpayer. ...