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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. ...

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. ...

Pursuant to a Declaration dated March 31, 2007, the taxpayer, in consideration for the “Amount” of US$160,033,328 and CHF 80,000, relinquished to GI his claims to the PPU and GS, and assigned all his GH shares to GH. ...

The conditions between mutually independent CFC and CAHPL could, however, include CAHPL situated within the Chevron group and CAHPL being subject to the direction of Chevron for the benefit of the Chevron group. 93 In such circumstances, were CAHPL seeking to borrow for five years on an unsecured basis with no financial or operational covenants from an independent lender, in order to act rationally and commercially and conformably with the interests of the Chevron group to obtain external funding at the lowest possible cost consistently with any relevant operational considerations, it would do so with Chevron providing a parent company guarantee, if such were available. 94 In the light of the evidence as to Chevron’s policy concerning external funding and its willingness to provide a guarantee to achieve that end the above is the natural and commercially rational comparative analysis when one removes the controlled conditions operating between CAHPL and CFC and replaces them with the condition of mutual independence. 95 In the circumstances there would have been a borrowing cost conformable with Chevron’s AA rating, which, on the evidence, would have been significantly below 9%. ...

Commissioner of Income Tax, International Taxation – 3, Delhi & Anr. (2017), Civil Appeal No. 3849 of 2017, 15 SCC 602-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 UK company with operational control over annually-recurring 3-day Grand Prix races in India had a PE (the racing circuit of a local company) A U.K. corporation (“FOWC”), which held all rights to commercially exploit the Formula One World (car-racing) Championships by virtue of an agreement with another company (“FOAM”), entered into an agreement (the “RPC”) with an Indian corporation (“Jaypee”) that, in consideration of US$40 million payable by Jaypee, Jaypee would host, stage and promote the Formula One Grand Prix event at a commercial racing circuit in India (the “Buddh International Circuit” or “circuit”) to be constructed by it (with FOWC also having the right to exploit the TV feed for the events, which it assigned to an affiliate). ...