Search - consideration

In finding that this fee was part of the consideration for the zero-rated vacation package, Dussault TCJ. noted (at p. 28-10) that "if one concludes that there is a supply separate from the supply of the vacation package it must be of 'a useful article or service'" and that, here, the alleged benefits attached to membership "represent nothing more than promotional literature used by Club Med for marketing its vacation packages at Club villages abroad" (p. 28-11). ...

MNR, 73 DTC 5264, [1973] CTC 295 (FCTD)-- summary under Paragraph 700(1)(d) Summary Under Tax Topics- Income Tax Regulations- Regulation 700- Subsection 700(1)- Paragraph 700(1)(d) The taxpayer transferred its logging operations to a subsidiary in consideration for an interest-bearing promissory note. ...

MNR, 93 DTC 1266 (TCC)-- summary under Compensation Payments Summary Under Tax Topics- Income Tax Act- Section 9- Compensation Payments Lease inducement payments received by the taxpayer were taxable to it given that they were found not to have been intended as reimbursements for the cost of tangible personal property but, rather, as consideration for the taxpayer becoming subject to an ongoing obligation to pay (deductible) rent, and given that the negotiation of leases was an important part of the taxpayer's business. ...

McGuckian, [1997] BTC 343 (HL)-- summary under Compensation Payments Summary Under Tax Topics- Income Tax Act- Section 9- Compensation Payments On 23 November 1979, the trustee who owned shares of a private company ("Ballinamore") assigned to a UK company the right to any dividend payable by Ballinamore in 1979 for consideration that was equal to 99% of the dividend that in fact was declared and paid by four days later. ...

Profit- Debt/ receivables Gains enjoyed by the taxpayer, upon the redemption of preferred shares held by her in a company and the partial payment of company indebtedness held by her, were fully taxable because, at the times that she acquired the shares and indebtedness for nominal consideration (1) she was sufficiently involved with her husband (who became president of the company) to make his intentions her own, and (2) his intention was a speculative one of rescuing the company from insolvency and making it profitable through his own efforts. ...

.$16.3 million that the taxpayer paid, at the same time that it purchased a business of the vendor, as consideration for the assignment to it of long-term supply contracts for feedstock, represented an expenditure on income account given that the particular expenditure was carefully segregated in a separate agreement and represented part of the operating cost to it of obtaining the feedstock. ...

Repairs or Running Expense In finding that the cost of a replacement engine for a power shovel was a capital expenditure, Cameron J. stated (at p. 1118) that he was influenced by the magnitude of the outlay (which exceeded the undepreciated capital cost of the shovel as a whole) and by the consideration that "the engine clearly was a marketable entity, readily detached from the power shovel by the removal of a few bolts, and capable of being used for other purposes". ...

.)-- summary under Section 8 Summary Under Tax Topics- Other Legislation/Constitution- Charter (Constitution Act, 1982)- Section 8 mere suspicion An investigation by CCRA of the taxpayer was not transmuted into a criminal investigation until the auditor met with Special Investigations and referred the file to them for their consideration. ...

.)-- summary under Subsection 231.1(1) Summary Under Tax Topics- Income Tax Act- Section 231.1- Subsection 231.1(1) An investigation by CCRA of the taxpayer was not transmuted into a criminal investigation until the auditor met with Special Investigations and referred the file to them for their consideration. ...

The Queen, 74 DTC 6585, [1974] CTC 763 (FCTD)-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) Following the acquisition of the shares of a company by the taxpayers for consideration that included a mortgage given by the company to the vendors, the company paid principal and interest on amounts borrowed by the taxpayers to acquire its shares, and also made payments of principal and interest under the mortgage. ...