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After assuming that the corporation was a “common carrier” (as referenced in Reg. 1104(2)), which CRA described as “a person who carries on the business of providing, for consideration, a service of transporting property or persons from one place to another and who generally offers its services to the public,” CRA stated: [P]roperty described in subparagraph (h)(ii) of Class 1 …, that is, property acquired after May 25, 1976, may be included in a railway system. ...

. … [I]f a person who ceases to be a partner, demonstrates that the person contributed to the creation of goodwill and receives payments in respect thereof, the payments could be consideration for the former partner's rights to partnership property and would, therefore, be payments of capital. … … A member who ceases to be a member of a partnership has an income interest in the partnership under subsection 96(1.1) if, inter alia, all the members agree to allocate a portion of the partnership's income to the member who has ceased to be a member of the partnership. ...

The Settlement Agreement stated that the Settlement Amount was paid to them “in consideration of the loss of entitlement to PRBs, the alleged violation of their Charter rights and discontinuing litigation … as general damages for future loss of PRBs...” ...

The Settlement Agreement stated that the Settlement Amount was paid to them “in consideration of the loss of entitlement to PRBs, the alleged violation of their Charter rights and discontinuing litigation … as general damages for future loss of PRBs...” ...

The consideration given by the employee is considered to be the employee's covenants as found in the collective agreement or in the contract of service. ...

12 January 2009 External T.I. 2008-0293901E5 F- Article 80-- summary under Commercial Debt Obligation Summary Under Tax Topics- Income Tax Act- Section 80- Subsection 80(1)- Commercial Debt Obligation de minimis interest deductibility on a debt could cause it to be a commercial debt obligation A small business corporation with nominal accumulated profits purchased for cancellation shares in its capital having nominal capital in consideration for the issuance by it of interest-bearing debt. ...

In responding affirmatively, CRA stated: …[T]he issued shares represent consideration for the employee surrendering their rights under the agreement. ...

9 May 2007 External T.I. 2006-0189931E5 F- Renonciation à une fiducie par un conjoint-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition extinguishment of trust interests on their renunciation is a disposition of the renounced interest, but resulting variation of trust to accelerate distribution entitlements is not Regarding the consequences of the renunciation by the beneficiary of a testamentary spousal trust of all entitlements under the trust (other than income that has accrued to date) without consideration, CRA stated: [The] definition of disposition is not exhaustive. ...

9 May 2007 External T.I. 2006-0189931E5 F- Renonciation à une fiducie par un conjoint-- summary under Paragraph 104(4)(a) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(4)- Paragraph 104(4)(a) variation of spousal trust, following renunciation by spouse, to accelerate distribution entitlement of residuary beneficiaries would not engage s. 104(4) until distribution The beneficiary of a testamentary spousal trust renounces all entitlements under the trust (other than income that has accrued to date) without consideration and without having indicated who was entitled to benefit from the renunciation. ...

9 May 2007 External T.I. 2006-0189931E5 F- Renonciation à une fiducie par un conjoint-- summary under Subsection 70(6) Summary Under Tax Topics- Income Tax Act- Section 70- Subsection 70(6) variation of spousal trust, following renunciation by spouse, to accelerate distribution entitlement of residuary beneficiaries would not deny s. 70(6) rollover The beneficiary of a testamentary spousal trust renounces all entitlements under the trust (other than income that has accrued to date) without consideration and without having indicated who was entitled to benefit from the renunciation. ...