Search - consideration

., 98 DTC 6275, [1998] 3 CTC 115 (FCA)-- summary under Subsection 79(2) Summary Under Tax Topics- Income Tax Act- Section 79- Subsection 79(2) The transfer by the taxpayer to his sister and former wife of his interest in two buildings in consideration for a reduction in the amount he owed to them was found to be a disposition whose proceeds of disposition were determined in accordance with s. 54(h)(i) (i.e., the "sale price of property that has been sold"), rather than by para. ...

., 94 DTC 6511, [1994] 2 CTC 170-- summary under Specified Investment Business Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Specified Investment Business at least six A practising lawyer who spent approximately 28 hours per year on telephone calls monitoring the business of the taxpayer in addition to making occasional visits to the taxpayer's office in consideration for annual remuneration from the taxpayer of $8,250 did not qualify as a "full-time employee". ...

That is a consideration which inclines a court to a rigorous scrutiny of the enactment before it, but it does not permit an interpretation that supplies what Parliament must be taken to have deliberately omitted. ...

Since the consideration for the instalments thus was the waiver of the contract benefits rather than the need of the recipient, the instalments were non-deductible. ...

Accordingly, "a transaction that clearly falls within the object and spirit of section 66 cannot be said to unduly or artificially reduce income merely because the taxpayer was influenced in deciding to enter into it by tax considerations." ...

Because Tranter was not in breach of the option agreement when Harvey agreed to surrender his option, the payment made to him was consideration for the disposition of his option (rather than damages for its breach) and accordingly was taxable. ...

The Queen, 2010 DTC 1016 [at at 2615], 2009 TCC 484 (Informal Procedure)-- summary under Class 14 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 14 A contract under which the taxpayer made a total contribution of $25,500 in consideration for a company agreeing to pay to the taxpayer 5.5% of the gross revenue from the operation of a lottery terminal in St. ...

The Queen, 74 DTC 6563, [1974] CTC 742 (FCTD)-- summary under Paragraph 6(3)(d) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(3)- Paragraph 6(3)(d) The taxpayer received a lump sum in consideration for relinquishing his rights under his existing employment contract, and it was agreed that he would continue on with the company as an employed consultant. ...

., 99 DTC 905, [1999] 4 CTC 2468 (TCC)-- summary under Paragraph 251(1)(c) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) largely overlapping boards of directors and substantial minority interest A transfer by the taxpayer of its interest as lessor in mining concessions and railway rights-of-way to a corporation ("CJC") in which a subsidiary of the taxpayer had a beneficial 37% interest was found to be a non-arm's length transaction given that the boards of the taxpayer and CJC had mostly overlapping directors and that one of those directors had determined that the transfer should occur for consideration that was 20% less than the appraised value of the leasehold interest. ...

.)-- summary under Incurring of Expense Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Incurring of Expense The taxpayer made an interest-bearing loan of $50,000 to some customers (two related trucking companies) in consideration inter alia for their agreement to purchase all their tires and tubes from the taxpayer. ...