Search - consideration

Furthermore, his conclusion that "a profit-oriented business person acting reasonably would not enter into the transactions, as described herein, in the absence of or excluding income tax considerations" violated the principle that "neither experts nor ordinary witnesses may give their opinions upon matters of legal or moral obligation, or general human nature, or the manner in which other persons would probably act or be influenced". ...

Subsidies which she received from the Province of New Brunswick to cover part of the costs of care for residents did not qualify as social assistance payments under s. 81(1)(h) given that they represented consideration for services provided by her in the course of her business of providing long-term care services. ...

MNR, 64 DTC 5041, [1964] CTC 40 (Ex Ct), briefly aff'd 66 DTC 5100, [1966] R.C.S. 354-- summary under Subsection 20(4) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(4) After finding that the taxpayer has sold depreciable property for proceeds of disposition in excess of the original capital cost, Dumoulin J. noted that, although a portion of the consideration represented a mortgage which would not be paid over an extended period of time: "The deferral of these debts creates no eventual prejudice to the appellant-vendor in the event of the financial ruin of the purchaser, since section 11(3d)... assures the former a sufficient amount of protection. ...

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. ...

Minister of National Revenue, 70 DTC 6366, [1970] CTC 572, [1971] S.C.R. 601-- summary under Proceeds of Disposition Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Proceeds of Disposition In rejecting an argument that recapture of depreciation should be reduced to reflect the fair market value of debentures received in consideration for the depreciable property being lower than their principal amount, Pigeon J. noted that s. 20(5)(c) of the pre-1972 Act deemed proceeds of disposition of the property to include the sale price, which was equal to the principal amount of the debentures. ...

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. ...