Search - consideration

MNR, 91 DTC 1147 (TCC)-- summary under Timing Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Timing In 1979 the taxpayer purchased an interest in a MURB from a promoter, in 1982 defaulted in making payments on a promissory note which he had given in consideration for his interest with the result that 1983 losses sustained on the project were absorbed by the promoter. ...

.)-- summary under Compensation Payments Summary Under Tax Topics- Income Tax Act- Section 9- Compensation Payments The taxpayer carrying on business as a theatrical agent and producer of plays, acquired the scenery, properties and costumes to a play for £1,000, and also obtained a five-year licence to perform the play in the United Kingdom outside London in consideration for a royalty. ...

.)-- summary under Paragraph 12(1)(x) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x) Before going on to find that a lump sum received by an actor in consideration for his covenant not to exercise his vocation for a period of 18 months was a tax-free receipt, Sir Evershed M.R. stated (at p. 145) that "many sums of money received in the course of carrying on a trade, but not as a result of the trade as it was contemplated that it would be carried on in the normal course, may nevertheless be taxable". ...

Profit- Copyright The taxpayer, together with another senior government lawyer, agreed with a publisher to compile an encyclopedia of legal forms for total consideration of $17,500 payable in instalments over such period of time as it might take them to prepare and complete the work. ...

Leslie, 75 DTC 5086, [1975] CTC 155 (FCTD)-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) no asset backing for note- no benefit until paid In 1959 the taxpayer sold his food storage business having a fair market value of $5,078 to a company of which he was the majority shareholder in consideration of treasury shares having an expressed value of $10,000 and a promissory note in the principal amount of $15,300. ...

MNR, 60 DTC 519 (TAB)-- summary under Proceeds of Disposition Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Proceeds of Disposition A "lease with promise of sale" between the taxpayer and the supposed lessee was found to be an agreement of sale given that its terms were fully consistent with a contract of sale, including the fact that the consideration was structured in the same manner as instalment payments, with provision being made for the separate payment of interest thereon, and in light of provision for conveyance of the property (a motel) to the lessee for $1 on payment of all the instalments. ...

The Queen, 2000 DTC 6302 (FCTD)-- summary under Paragraph 20(1)(n) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(n) The taxpayers, who had sold their interest in a property for consideration that included their covenant to continue paying all balances owing on mortgages secured on the property, were not entitled to claim a reserve with respect to amounts still owing in respect to those mortgages at the end of their 1971 taxation year given that the purchaser had, in turn, sold the same property to another purchaser who had assumed such mortgages. ...

MNR, 53 DTC 338 (ITAB)-- summary under Substance Summary Under Tax Topics- General Concepts- Substance Payments received by the taxpayer which were stipulated to be consideration for his agreement not to engage in the lobster business within two specified counties were found not to be employment income to him pursuant to what now is s. 6(3)(e) because of the words in that provision referring to "irrespective... ...

., 2015 QCCA 838, aff'd 2016 SCC 55-- summary under Foreign Accrual Property Income Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(1)- Foreign Accrual Property Income FAPI from loan by CFA to Canco The taxpayer implemented a plan, to neutralize the effect of FX fluctuations on its investment in a U.S. sub, that overlooked FAPI considerations – so that interest on a loan made by the sub back to Canada was included in the taxpayer's income. ...

Profit- Patents and Know-How The taxpayer, which had acquired letters patent relating to a galvanizing process, granted to a manufacturer of ammunition boxes a licence to use the process within the United Kingdom to manufacture up to 75,000 ammunition boxes for a period of up to approximately 12 years, in consideration for a "capital sum" of £3,000 and a royalty of 3d. per box. ...