Search - consideration

Two agreements were signed under which Beaupré sold his shares in the company to Phillips for $12,000 and agreed to be a consultant for consideration of $48,000 consisting primarily of monthly payments to be made by the company which could continue after Beaupré's death. ...

Profit- Shares Shares in mining companies received by a partnership (which had been formed in order to stake claims) as partial consideration for the sale of mining properties of the partnership, were received in the course of the partnership's business. ...

The taxpayer had the right upon the termination of his employment to surrender his net profits interest in consideration for a cash payment. ...

The Queen, 87 DTC 5202, [1987] 1 CTC 305 (FCTD), aff'd 91 DTC 5540 (FCA)-- summary under Element F Summary Under Tax Topics- Income Tax Act- Section 66.2- Subsection 66.2(5)- cumulative Canadian development expense- Element F In 1969 the taxpayers agreed to transfer their coal licences in consideration for $200,000 and the covenant of the purchaser ("CNI") to pay $600,000 out of CNI's first revenues from the sale of any coal from operation of the licences, or out of proceeds from any disposition of the licences. ...

Profit- Debt/ receivables As part of the purchase by the taxpayer of a car dealership (which was determined to be a capital transaction) the taxpayer acquired a loan payable by the company to the vendor shareholder for no consideration. ...

The reviewing court should consider whether the discretion was 'exercised in good faith and, where required, in accordance with principles of natural justice, and where reliance has not been placed upon considerations irrelevant or extraneous to the statutory purpose'.... ...

As the CRA had thus committed an error by failing to consider that the interest on the penalty might be reversed on the basis of fairness considerations, the taxpayer's request for fairness review of such interest was returned to the Minister for reconsideration. ...

Expense- Marketing Expenditures A large lump sum payment was made by the taxpayer to the City of Calgary in consideration of (i) the City improving the system of roads around the taxpayer's shopping centre and (ii) an implied promise of the City not to assess the taxpayer for local improvement taxes in respect of the cost of such improvements. ...

The Queen, 76 DTC 6362, [1976] CTC 639 (FCTD), aff'd 77 DTC 5244 [1977] CTC 388 (FCA), aff'd 78 DTC 6566, [1978] CTC 780, [1979] 1 S.C.R. 36-- summary under Investment Contract Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(11)- Investment Contract In finding that an agreement, under which in consideration for a payment of $4 million the taxpayer obtained certain rights and privileges to produce and take petroleum from lands, did not represent a loan, Cattanach J. stated (at p. 6368): The essence of a loan is that the advance shall be repaid. ...

The Queen, 76 DTC 6362, [1976] CTC 639 (FCTD), aff'd 77 DTC 5244 [1977] CTC 388 (FCA), aff'd 78 DTC 6566, [1978] CTC 780, [1979] 1 S.C.R. 36-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) The taxpayer borrowed $4 million (apparently at a commercial rate of interest) from its banker and paid that sum to Amoco in consideration of Amoco conveying certain working interests to the taxpayer, provided that the working interests would revest in Amoco when the taxpayer received $4 million in cash or the equivalent in petroleum substances, together with interest at 3% per annum. ...