Search - consideration

Accordingly, that activity of the City was engaged in for no consideration and, therefore, represented an exempt supply by virtue of s. 10 of Part VI of Schedule V. ...

Humphrey (1948), 30 TC 235 (HL)-- summary under Computation of Profit Summary Under Tax Topics- Income Tax Act- Section 9- Computation of Profit The taxpayer transferred mining concessions to a newly-incorporated company in consideration for shares of the company contemporaneously with an initial public offering of shares of the company. ...

The Queen, 75 DTC 5274, [1975] CTC 472 (FCTD)-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) In June 1967 a company ("Brilund") agreed to issue shares then worth no more than $120,000 to a non-resident shareholder, in consideration of past services rendered by him, but did not issue the shares to him until December, when the shares were worth substantially more. ...

S.140 did not apply to the appellant given that it did not issue shares in consideration for the capital contributions nor was there any evidence that payment of the capital contributions by the shareholders was a condition of the shareholders obtaining membership in the taxpayer (they already were shareholders). ...

MNR, 91 DTC 1147 (TCC)-- summary under Timing Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Timing In 1979 the taxpayer purchased an interest in a MURB from a promoter, in 1982 defaulted in making payments on a promissory note which he had given in consideration for his interest with the result that 1983 losses sustained on the project were absorbed by the promoter. ...

.)-- summary under Compensation Payments Summary Under Tax Topics- Income Tax Act- Section 9- Compensation Payments The taxpayer carrying on business as a theatrical agent and producer of plays, acquired the scenery, properties and costumes to a play for £1,000, and also obtained a five-year licence to perform the play in the United Kingdom outside London in consideration for a royalty. ...

The Queen, 93 DTC 965, [1993] 2 CTC 2658 (TCC)-- summary under Subsection 244(14) Summary Under Tax Topics- Income Tax Act- Section 244- Subsection 244(14) The assumption by another corporation ("Polar Oils") of the obligation of the taxpayer to pay $119,658 in consideration for the taxpayer's agreement to pay four cents per litre more for diesel fuel purchased by it from Polar Oils until the total overpayments amounted to $119,658, constituted an inducement under s. 12(1)(x). ...

Profit- Partnership Interests partnership interest buyback not distribution It was found that a sum of $103,111 paid by a partnership to a retiring partner was consideration for the buying back of his partnership interest rather than an allocation to him of partnership income, including his interest in unbilled work in progress. ...

Notwithstanding submissions of the taxpayers that they regarded their shares as being worth more than $300,000 and that the covenant likely was unenforceable, it was found that the covenant had value to the purchasers and that the payments in consideration of the covenant were employment income. ...

The Queen, 2009 DTC 912, 2009 TCC 295-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt no evidence of payment through off-settable cash Promissory notes owing by the taxpayers, which were consideration for their acquisition of units of a limited partnership, provided that the interest thereon was to be paid by way of set-off against distributions otherwise payable by the partnership to the taxpayers. ...