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The Queen, 95 DTC 155 (TCC)-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition amendment of agreement did not entail its transfer A payment of $575,000 to the taxpayer by a debtor in default in consideration for an extension of the due date of the loan and the taxpayer's agreement to waive its current rights to take action on the loan, did not represent proceeds of disposition of property. ...

Profit- Goodwill Upon being advised by its Indian distributor ("Ralli") that the taxpayer (which carried on business as a mechanical and electrical engineer) risked having the import of its tools into India being banned by the Indian government, the taxpayer and Ralli incorporated an Indian joint-venture company ("Ralliwolf") to manufacture in India selected lines of the taxpayer's tools for distribution in India, and 45% of the shares of Ralliworth were issued to the taxpayer in consideration for the transfer by the taxpayer to Ralliworth of plant and equipment, and various drawings, designs and other know-how, and for the taxpayer's covenant to "keep out" of India for 10 years. ...

To extend privilege to accountants would entail policy considerations more appropriate for Parliament. ...

Profit- Contracts After a decision to go out of the pulpwood business and into the business of manufacturing fence posts, the taxpayer assigned its contract to supply pulpwood to another company ("Weyerhaeuser") to two companies for valuable consideration. ...

Bentley was considered under the Finance Act 1965 to have acquired, on her father's death in 1967, a 1/6 share of real property situate in West Germany which passed to her for a consideration equal to its fair market value, and sold her interest for DM in 1973. ...

Most administrative functions of the taxpayer's business were handled by Enterprise Foundry in consideration for a fee equal to a percentage of the taxpayer's purchases from Enterprise Foundry. ...

MNR, 64 DTC 428 (TAB)-- summary under Subparagraph 212(1)(d)(i) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(d)- Subparagraph 212(1)(d)(i) variable payments wer for use of knowhow The taxpayer entered into a written agreement for the provision to it in the United States by an American company of technical advice and assistance in consideration for payments of $50,000 per annum (for the first two years of the agreement) and 0.75% of net sales (for the balance of the agreement). ...

Expense- Know-How and Training The taxpayer agreed with a U.S. corporation ("Moore") that in consideration for an exclusive licence for the use in Canada by the taxpayer of Moore's technical information respecting methods for manufacturing and producing flexible tubes, the taxpayer would pay $25,000 on signing plus an additional formula royalty based on its sales from the related products. ...

Expense- Lessening of Competition The taxpayer agreed with a U.S. corporation ("Moore") that in consideration for an exclusive licence for the use in Canada by the taxpayer of Moore's technical information respecting methods for manufacturing and producing flexible tubes, the taxpayer would pay $25,000 on signing plus an additional formula royalty based on its sales from the related products. ...

The Queen, 97 DTC 1328 (TCC)-- summary under Subsection 248(10) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(10) On September 10, 1988, the taxpayer transferred its assets to a subsidiary ("Alimentation 1988") in consideration for a demand promissory note and 506,125 Class B shares having a redemption value of $1 per share and nominal paid-up capital. 151,125 of the Class B shares were redeemed in the fiscal years of Alimentation 1988 ending on May 31, 1990, 1991 and 1992. ...