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The authorities establish that interest income may be derived when accrued and that the taxpayer’s business and income earning activities, and the place of interest income in that business or activities, are relevant considerations to whether interest has been derived, in the sense of having come home, when accrued or only when received. … SRC[‘s]…assets during that period were essentially cash and receivables, intracompany debts and shares in its subsidiaries. ...

However, after stating (at para. 22) that he accepted the conclusion in Sherway Centre that “an amount paid as compensation for the use of money for a stipulated period can be said to accrue day-to-day,” McEwen J found that the Discount Fee constituted interest, stating (at para. 45): … [I]t is my view … the Discount Fee meets the three … elements of interest: it is consideration or compensation for the use or retention of money owed to ClearFlow; it related to the principal amount; and, it accrued over time (literally day-to-day). ...

. … Whether the interests of the applicants in Talison Lithium also passed the principal asset test, for the purposes of s 855-25(1)(b), requires consideration of whether 50% or more of the market value of the assets of Talison Lithium were attributable to Australian real property. ...

., close to half) to a wholly-owned personal holding company (a “Holdco”) in consideration for preferred shares which, after giving effect to the joint election made under the Quebec equivalent of s. 85(1) (limiting the taxable capital gain recognized by him in each year to $250,000) had a paid-up capital equal to their deemed cost. ...

It only leaves for consideration the consequences of a reduction in capital. ...

Pike held special voting shares) in consideration for non-voting common shares of the Child Corporation. ...

All that appears to have happened was that monies were directed straight to [the GE affiliate] without negotiating terms or the consideration at a director level as would have been expected from a company carrying on commercial activities on sound business principles. ...

Singapore Telecom Australia Investments Pty Ltd v Commissioner of Taxation, [2021] FCA 1597, aff'd [2024] FCAFC 29-- summary under Article 9 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 9 loan with interest that would vary significantly depending on whether cash flow conditions were met would not have been agreed to by independent enterprises A Singapore-resident company (“SAI”) transferred the shares of a recently-acquired Australian telecom company (“SOPL”) to an Australian subsidiary (“STAI”) in consideration for common shares and $5.2B in unsecured notes which had a term of approximately 10 years and bore interest at a floating rate equal to the 1 year bank bill swap rate (“BBSR”) plus 1%, but multiplied by a gross-up factor of 10/9 to reflect that the interest was subject to withholding tax. ...

. … Since the court has concluded that we are in the presence of a single supply for which the consideration, following the resolution of the sales, was reduced to nil, QSTA section 448 applies, especially since it is not disputed that the requirements of QSTA section 449 are satisfied. ...

Pursuant to a Declaration dated March 31, 2007, the taxpayer, in consideration for the “Amount” of US$160,033,328 and CHF80,000, relinquished to GI his claims to the PPU and GS, and assigned all his GH shares to GH. ...