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The consideration for each ordinary share was US$3.55 per share and US$7.10 per ADS. ...

After canvassing authorities on the concept of a reasonable deduction, including (at para. 29) the statement in Gabco that this was a question of whether “no reasonable business man would have contracted to pay such an amount having only the business consideration of the appellant in mind,” and (at para. 31) that in Petro-Canada that “[t]here may be circumstances in which a decision to pay more than fair market value for something is a reasonable decision,” and then stated (at paras. 53-54): [I]n this case interest at the 10% rate deducted by the appellant is literally in the middle of the range of reasonable rates established by Deloitte's accountants, that is, between 7.89%, the rate used by the respondent to assess it, and 12.39%, this range having been established by considering, among other things, rates for unsecured loans. ...

Agence du revenu du Québec, 2021 QCCQ 3891-- summary under Subsection 120.4(5) Summary Under Tax Topics- Income Tax Act- Section 120.4- Subsection 120.4(5) kiddie tax applicable to a trust’s distribution of a capital gain, realized on a crystallization transaction, to a minor beneficiary In 2012, a discretionary family trust engaged in a capital gains crystallization transaction in which it disposed of shares, having a modest ACB, of a corporation wholly-owned by the trust and engaged in a health care business (“Médicus”) in consideration for shares of a new class of Médicus, having a value of around $1M. ...

JDI then almost immediately acquired the PCE from IOL for $120 million (claiming 100% of this amount as CCA for that year), and agreed to operate the PCE in consideration for “throughput fees” payable to it by IPPL pursuant to “Operating and Services Agreements” (“OSAs”) governed by New Brunswick law. ...

Skolrood JA found that there were no reversible errors in the findings of the chamber judge that it was appropriate to “unbundle” the single consideration that GFL charged on a monthly basis to its customers for BC PST purposes: 80% to the non-taxable waste disposal service; and 20% to the taxable lease of the toilets and to the cleaning services provided “to” the toilets. ...

ECL assigned the loan note to a Honduras company ("Industrias") which was also owned by ECL, in consideration of the issue by Industrias to ECL of loan notes with the same principal amount and carrying interest at 4% p.a. ...

. … Under Article 5(2)(i) of the DTAA, the relevant consideration is the continuity of business presence in aggregate – not the length of stay of each individual employee. ...

Accordingly, the shares of the wives in S & D were purchased for cancellation in consideration for the transfer of lands of S & D to a corporation owned equally by the wives. ...

The Court questioned the implicit assumption in the question that the NEC booking fees were consideration for a separate supply. ...

In August 2006, the trustees of the Family Trust transferred a directly held portfolio on a rollover basis to a limited partnership (“CAL Equities”) in consideration for a limited partnership interest. ...