Search - consideration

However, it is common ground that the substitution of the new RMC shares for the old ones was deemed by section 86 to be a disposition of the old shares in consideration for the new ones. ...

"[T]he appellant has parted with the possession of the heaters in consideration of a monthly rental and it has no capital asset that has been improved or created by the expenditure of the installation costs... ...

Miller J below that a lump sum payment received by the taxpayer from the sole tenant of its building in consideration for the termination of the lease was received on income account. ...

Parsons, 84 DTC 6447, [1984] C.T.C 354, 84 DTC 6452 (FCA)-- summary under Sham Summary Under Tax Topics- General Concepts- Sham no sham as purported legal rights were created It was found by the trial judge that management companies, which two professional engineers ("Parsons" and "Vivian") had incorporated and interposed between themselves and an engineering firm ("Design") of which they had been employees until that time, "(1) had no bona fide business purpose, (2) had, primarily, the purpose of directly reducing their income tax liabilities [and] (3) had, secondarily, an estate planning purpose which... must be taken to have also been solely motivated by tax and personal, not business, considerations." ...

Parsons, 84 DTC 6447, [1984] C.T.C 354, 84 DTC 6452 (FCA)-- summary under Tax Avoidance Summary Under Tax Topics- General Concepts- Tax Avoidance no sham as purported legal rights were created It was found by the trial judge that management companies, which two professional engineers ("Parsons" and "Vivian") had incorporated and interposed between themselves and an engineering firm ("Design") of which they had been employees until that time, "(1) had no bona fide business purpose, (2) had, primarily, the purpose of directly reducing their income tax liabilities [and] (3) had, secondarily, an estate planning purpose which... must be taken to have also been solely motivated by tax and personal, not business, considerations." ...

Parsons, 84 DTC 6447, [1984] C.T.C 354, 84 DTC 6452 (FCA)-- summary under Related Companies Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Related Companies It was found by the trial judge that management companies, which two professional engineers ("Parsons" and "Vivian") had incorporated and interposed between themselves and an engineering firm ("Design") of which they had been employees until that time, "(1) had no bona fide business purpose, (2) had, primarily, the purpose of directly reducing their income tax liabilities [and] (3) had, secondarily, an estate planning purpose which... must be taken to have also been solely motivated by tax and personal, not business, considerations." ...

Parsons, 84 DTC 6447, [1984] C.T.C 354, 84 DTC 6452 (FCA)-- summary under Related Companies Summary Under Tax Topics- Income Tax Act- Section 9- Related Companies It was found by the trial judge that management companies, which two professional engineers ("Parsons" and "Vivian") had incorporated and interposed between themselves and an engineering firm ("Design") of which they had been employees until that time, "(1) had no bona fide business purpose, (2) had, primarily, the purpose of directly reducing their income tax liabilities [and] (3) had, secondarily, an estate planning purpose which... must be taken to have also been solely motivated by tax and personal, not business, considerations." ...

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. ...