Search - consideration

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. ...

The Queen, 97 DTC 1328 (TCC)-- summary under Subsection 55(2) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2) 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. ...

An amount so paid by the taxpayer was a capital expenditure given that this obligation was part of the consideration for the acquisition by the taxpayer of the lease, which was a capital asset. ...

Having regard to the contingency factor involved, the wording of these sections excludes the amounts now under consideration, even if they be termed a liability instead of a reserve. ...

.)-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition The taxpayer entered into an agreement with General Electric to cause its wholly-owned subsidiary to sell to General Electric the shares of three companies for stipulated sums and provided a non-compete covenant to General Electric in consideration for a further lump sum. ...

[T]he payments were received by the taxpayer as consideration for a once and for all disposal of a right or advantage appurtenant to the land; namely the right or advantage of using it for dumping. ...

Together with her consideration of the use of the land as a pulp mill, this finding informed the judge’s conclusion that the object of annexation was for the better use of the land and that the items of machinery and equipment had therefore become fixtures. ...

Alberta, 2016 ABQB 334, rev'd 2018 ABCA 147-- summary under Section 67 Summary Under Tax Topics- Income Tax Act- Section 67 Gabco test implies a range Before finding that interest payable by the appellant on a subordinated intercompany note bearing interest at 11.5% was in a “reasonable amount” as required by s. 20(1)(c) notwithstanding that it may have exceeded an arm’s length rate, Poelman J stated (at para. 117): The Gabco test adopts the perspective of the borrower’s business considerations…. ...

. … As I construe subsection 84(3), a corporation is deemed to have paid a dividend at the time of the acquisition of its shares and, even if the consideration for the shares acquired is payable over a considerable period of time, it must, for the purposes of income tax law, be regarded as being payable at the time of the acquisition. ...