Search - consideration

Profit- Patents and Know-How The plaintiff granted a licence to the defendants for a period of five years to make and sell artificial legs pursuant to a patent of the plaintiff in consideration for a fixed sum of £3,000 (£1,000 down and the remainder by instalments). ...

The agreement signed by the taxpayer indicated that the income tax payable resulting from the proposed change would be subject to interest at the prescribed rate, there was no incorrect advice given by an auditor that the reassessment would not result in income tax being owing, the Minister did not act in bad faith, and there was no breach of the principles of fundamental justice or consideration of extraneous or irrelevant factors. ...

Profit- Debt/ receivables The taxpayer, who was the general manager of a corporation ("HSS"), acquired debt of another corporation ("LTM") for consideration that was found by the Court to be nominal. ...

The Queen, 97 DTC 517 (TCC)-- summary under Computation of Profit Summary Under Tax Topics- Income Tax Act- Section 9- Computation of Profit cost of shares acquired in consideration for largely worthless loan obligation was nil In connection with the acquisition of the shares of a corporation ("LTM") by another corporation ("HSS") of which the taxpayer was the general manager, the taxpayer used the proceeds of a daylight loan to advance money to LTM, LTM loaned the same sum to its shareholders, the shareholders loaned the same sum to the taxpayer on a non-interest bearing basis with the principal not being due for approximately 100 years, and the taxpayer used the sum to pay off the daylight loan. ...

Profit- Copyright An author, who desired to raise substantial sums of money, agreed with her publishers that in consideration of £750 paid in three instalments she would grant them the sole and exclusive right throughout the term of her copyright to three already published novels to publish further editions of those novels in volume form throughout most of the British Commonwealth. ...

Benson's Hosiery (Holdings) Ltd. (1979), 53 TC 241 (HL)-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition A payment of 50,000 pounds by a marketing director to his employer, the taxpayer, in consideration of his release from his service contract was held to constitute the disposal of an "asset" within the meaning of s. 22(1) (quoted above). ...

Benson's Hosiery (Holdings) Ltd. (1979), 53 TC 241 (HL)-- summary under Property Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Property A payment of £50,000 by an employee to his employer in consideration of his employer releasing him of all obligations under the employment contract was held to be a capital sum chargeable to capital gains tax under the Finance Act, 1965 (U.K.). ...

., 97 DTC 5295 (FCA)-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) The taxpayer acquired units in limited partnerships that had incurred Canadian exploration expense and then, within 24 hours and after the occurrence of the partnership year ends, resold their units for nominal consideration pursuant to "put" agreements. ...

MNR, 50 DTC 398 (ITAB)-- summary under Paragraph 12(1)(g) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(g) An agreement for the assignment by the taxpayer to a drug company of the taxpayer's rights under patent to a medicinal preparation in consideration for a down payment of $1,000, and for $999,000 to be paid at a specified rate for each capsule sold by the purchaser, gave rise to income receipts to the taxpayer under s. 3(1)(f) of the Income War Tax Act. ...

On this basis, Vinelott J. accepted the Crown's concession (p. 392): that given that the obligation to remove the [equipment] was imposed by the license and that acceptance of it was in substance part of the consideration given by the consortium for the right to win oil from the North Sea, the expenditure when incurred will be expenditure wholly and exclusively incurred for the purpose of the company's trade even if on the abandonment of the Argyll Field the company's trade comes to an end. ...