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For the purposes of this Article, "fees for included services" means payments of any kind to any person in consideration for the rendering of any technical or consultancy services (including through the provision of services of technical or other personnel) if such services: (a) are ancillary and subsidiary to the application or enjoyment of the right, property or information for which a payment described in paragraph 3 is received; or (b) make available technical knowledge, experience, skill, know-how, or processes or consist of the development and transfer of a technical plan or technical design. ... Technology will be considered "made available" when the person acquiring the service is enabled to apply the technology. … [P]ayment of consideration would be regarded as "fee for technical/included services" only if the twin test of rendering services and making technical knowledge available at the same time is satisfied. … [I]t is not even the case of the Assessing Officer that the assessee, i.e. recipient of services was enabled to use these services in future without recourse to BT Canada. ...

Ltd. to Old Flora for consideration consisting of a promissory note for $1,951,457 and a Class A Preferred share worth $1. ... Business Corporations Act (the “BCA”) to correct this “corporate” mistake by changing the consideration to a promissory note for $1 and Class A Preferred Shares for 1,951,457. ...

When GAM proposed that SLT be merged with another fund managed by GAM in which non-residents were investors, it was agreed that, in light of the merged fund being subject to a higher level of fees than those to which SLT had been subject, that a Bermuda company owned indirectly by two Steinberg and Ludmer non-resident trusts would receive annual “fees” from the time of the 1994 merger that effectively represented a rebate of the higher fees imposed on the Canadian investors (although they were described to be consideration for services that, in fact, were never provided). ... Moreover, there is also the issue of the contracts which state that Sandringham was receiving the payments in consideration for “investment consultancy services”. ...

Expense- Contract Purchases or Prepayments lump sum payments made to lock-up doctors as customers for a 5-year period were currently deductible The taxpayer was an Australian public company that provided (including, relevantly, through a subsidiary trust (“Idameneo”) whose results were consolidated for tax purposes with its own medical centre facilities and services to doctors in consideration for 50% of the fees generated by them. In order to induce a doctor to join one of the medical centres operated by it, it would typically pay a lump sum in the range of $300,000 to $500,000 to the doctor in consideration for the doctor’s promise to conduct his or her practice from the medical centre for a specified period (generally around five years) and not to provide medical services to anyone within a radius of, say, 7km of the medical centre or the doctor’s own former practice at that practice’s previous location within that period. ...

In the same month, JDI acquired the PCE from IOL for $120 million (claiming that amount in CCA thereon for 2002), and agreed to operate the PCE in consideration for “throughput fees” and cost reimbursements payable to it by IPPL pursuant to “Operating and Services Agreements” (“OSAs”) governed by New Brunswick law. ... In particular, although the OSAs provided that the taxpayer (and then IRF) was to operate the PCE, the taxpayer delegated to IPPL, in consideration for fees, the performance of all the such operating services, so that nothing had changed “on the ground.” ...

Expense- Current expense vs. capital acquisition lump sum payments made to lock-up doctors at medical centres effectively controlled by the payer were capital expenditures A subsidiary (“Idameneo”) of an Australian public company provided medical centre facilities and services to doctors in consideration for 50% of the fees generated by them. In order to induce a doctor to join one of the medical centres operated by it, it would typically pay a lump sum in the range of $300,000 to $500,000 to the doctor in consideration for the doctor’s promise to conduct his or her practice from the medical centre for a specified period of around five years, along with an exclusivity covenant. ...

This amount can reasonably be considered to be part of the consideration for the disposition of property (the Building) of the taxpayers (the Appellants), and the remainder of this amount can reasonably be considered to be part of the consideration for the disposition of the property of 9118, namely the goodwill and other moveable property of the SR. ...

This explains why a similar provision in federal legislation has been commented on as follows: such a provision "does not have the effect of deeming the consideration received by the seller to be equal to the fair market value of property sold in a transaction between related persons if this consideration is greater than the market value" [citing Colubriale at para. 28]. ...

Agence du revenu du Québec, 2024 QCCQ 1195-- summary under Subsection 152(9) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(9) ARQ request to change the sales tax provision on which its assessment was founded was rejected After speaking with counsel for the ARQ about three weeks before the scheduled trial date, the ARQ auditor concluded that Autonun should have been assessed pursuant to QSTA s. 318 (similar to ETA s. 182, regarding amounts forfeited to a taxable supplier being deemed to be inclusive of tax), rather than pursuant to QSTA s. 92 (similar to ETA s. 168(9), regarding deposits not being taxable consideration until applied as consideration) on which the assessment of Autonun had been based. ...

The Queen, 75 DTC 5274, [1975] CTC 472 (FCTD)-- summary under Shares Summary Under Tax Topics- General Concepts- Fair Market Value- Shares The taxpayer was granted the right to acquire 300,000 shares of a corporation in consideration of past services in June of 1967 and the shares were issued to him in December. ...