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Agence du revenu du Québec, 2024 QCCQ 1195-- summary under Subsection 152(9) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(9) ARQ request to change the sales tax provision on which its assessment was founded was rejected After speaking with counsel for the ARQ about three weeks before the scheduled trial date, the ARQ auditor concluded that Autonun should have been assessed pursuant to QSTA s. 318 (similar to ETA s. 182, regarding amounts forfeited to a taxable supplier being deemed to be inclusive of tax), rather than pursuant to QSTA s. 92 (similar to ETA s. 168(9), regarding deposits not being taxable consideration until applied as consideration) on which the assessment of Autonun had been based. ...

The Queen, 75 DTC 5274, [1975] CTC 472 (FCTD)-- summary under Shares Summary Under Tax Topics- General Concepts- Fair Market Value- Shares The taxpayer was granted the right to acquire 300,000 shares of a corporation in consideration of past services in June of 1967 and the shares were issued to him in December. ...

"The word 'wilfully' as used in the subsection under consideration, carries a distinct connotation of deliberate purpose and ulterior motive. ...

., [1961] 2 All E.R. 167 (HL)-- summary under Resolving Ambiguity Summary Under Tax Topics- Statutory Interpretation- Resolving Ambiguity [T]he prevailing consideration must be that the taxpayer should not be put to any risk of being charged with a higher amount of profit than can be determined with reasonable certainty. ...

.), rev'd [1980] BTC 239 (HL)-- summary under Paragraph 69(1)(b) Summary Under Tax Topics- Income Tax Act- Section 69- Subsection 69(1)- Paragraph 69(1)(b) "[T]he ordinary primary meaning of 'gift' is a voluntary transfer of property made without consideration." ...

MNR, 58 DTC 676 (TAB)-- summary under Subparagraph 20(1)(p)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(p)- Subparagraph 20(1)(p)(i) The consideration received by the taxpayer on the sale of a theatre, which gave rise to recapture of depreciation to it, included the assignment to it of a debt owing by the purchaser. ...

Customs and Excise Commissioners, [2000] BTC 5153 (QBD)-- summary under Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Supply The surrender of hand guns by the taxpayer to the government and the receipt of compensation therefor constituted a supply for consideration given that there was a transfer of title to the government. ...

James' Chambers in consideration for a percentage of the gross fees of each barrister, did not hold an "office". ...

Among other things, none of the stipulated consideration was ever paid by the holding company and the directors of READ did not approve the transfer as required by the articles. ...

.)-- summary under Paid-Up Capital Summary Under Tax Topics- Income Tax Act- Section 89- Subsection 89(1)- Paid-Up Capital stated capital increase equal to principal of converted debt With respect to s. 23 of the Ontario Business Corporations Act … the effect of the conversion [of] a debt security into shares releases the corporation from liability for the principal amount of the debt security and that constitutes the consideration for the issuance of the shares. ...