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Results 1331 - 1340 of 28958 for consideration

Adams v. R., (sub nom. R. v. Adams) 98 D.T.C. 6266, [1998] 2 C.T.C. 353 -- summary under Paragraph 6(1)(e)

In overturning a finding of the Tax Court that in these circumstances s. 6(1)(e) did not apply because the taxpayers did not have "unrestricted use" of the automobiles, Robertson J.A. found (at p. 6270) in light of the broad language of s. 6(1)(e) and its legislative history that "the purpose for which the employer's automobile was made available is not a relevant consideration". ...

Barwicz v. The King, 2024 TCC 93 -- summary under Other

In finding that these distributions did not entail the taxpayer giving consideration to the trust for s. 160 purposes, Gagnon J found that: “the trustee's distributions had no impact on the rights of a beneficiary of the Trust who had or had not received a distribution” (para. 65, TaxInterpetations translation); and although the taxpayer “had a right under the Trust to be considered by the trustee for any distribution on the same basis as the other beneficiaries … there is no reason to believe that anyone would have paid even a very small amount for [this right]” and “[i]n fact, it is highly unlikely that such a right could be transferred to a third party” (para. 67). ...

Madison Pacific Properties Inc. v. Canada, 2025 FCA 20 -- summary under Subsection 245(4)

Canada, 2025 FCA 20-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) Deans Knight applied to corporate restart plan Under a “restart” plan, the appellant changed its name, spun out its existing mining assets so that it was a shell with only tax losses, and B.C. real estate companies of two individuals (Grippo and Heung) transferred various real estate assets, including jointly owned properties, to the appellant for consideration that included shares of the appellant. ...

Vanex Truck Service Ltd. v. Canada, 2001 FCA 159 -- summary under Agency

In finding that the insurance charges made by it represented consideration for a taxable resupply, Malone JA stated: [I]t was the right to the protection offered by the fleet policies which constituted a taxable supply of service under the provision of section 123. ...

Matte v. The King, 2025 TCC 16 -- summary under Investment Contract

Ouimet J went on to find that the contemplation by the notes’ terms that they could be forgiven in the discretion of the employer had “no impact on the legal effect of the documents” and that it did “not matter what considerations led to the loans” (para. 60) (here, meeting the employer’s performance conditions). ...

Canada v. Larsen, 99 DTC 5757 (FCA) -- summary under Paragraph (a)

Larsen, 99 DTC 5757 (FCA)-- summary under Paragraph (a) Summary Under Tax Topics- Income Tax Act- Section 110.6- Subsection 110.6(1)- Qualified Farm or Fishing Property- Paragraph (a) timber was an incorporeal hereditament in land and, thus, real property The taxpayer and his three siblings gave a lumber company the right to enter their land to remove timber during a five-month period for consideration of $70 per cubic metre of timber removed. ...

2017 Ruling 2016-0660321R3 - Reorg of REIT to simplify multi-tier structure -- summary under Qualifying Exchange

After the settling of a new unit trust (“MFT”), having redeemable retractable units, by a Canadian-resident third party, the Fund subscribes for MFT units for nominal cash consideration and the unit of the settlor is redeemed. ... Partnership will transfer all of its Opco Shares and Note to MFC in consideration for MFC Class B Shares (having similar attributes to the MFC Class A Shares), with the s. 85(2) election to be filed by Amalco MFC and Partnership. ... GP II will sell its undivided interest in each property to Partnership for fair market value consideration and then will be wound up. ...

2013 Ruling 2011-0397081R3 - Bump Transaction -- summary under Subclause 88(1)(c)(vi)(B)(III)

Plan of Arrangement for Target Each Target Share held by a dissenting shareholder was deemed to be transferred to BidAmalco in consideration for a right to be paid fair value. ... Each Target Class A Share was transferred to BidAmalco for cash consideration. ... Buyer XX Holdco transferred the shares of Buyer XX Opco to Mergeco in consideration for common shares in the capital of Mergeco. ...

31 August 2005 Internal T.I. 2005-0134831I7 F - Capital Gains Exemption Strip -- summary under Paragraph 84.1(1)(a)

Subsequently, each brother disposed of all their shares of Holdco 1 or Holdco 2 to two new respective personal holding companies (Holdco 3 or Holdco 4) in consideration for Class A common shares (having a nominal ACB and PUC in light of a s. 85(1) election) and for Class E preferred shares (also with a nominal PUC, but with a high ACB pursuant to s. 85(1)(g).) ... Each brother then disposed of such common shares to a new respective holding company (Holdco 5 or Holdco 6) in consideration for Class B preferred shares of such new Holdco, and also in consideration for Class A commons shares. ... The Directorate stated: [P]aragraph 84.1(1)(a) would not apply to the disposition by each of Brother 1 and Brother 2 of the Class A shares … of Amalco 1 or Amalco 2 … to reduce the ACB in respect of the Class B preferred shares … of Holdco 5 and Holdco 6 received as consideration. … [F]or the purposes of paragraph 84.1(1)(a), the ACB to Brother 1 or Brother 2 … of the Class A shares of Amalco 1 or Amalco 2, as the case may be, would technically be deemed to be approximately $XXXXXXX. ...

2017 Ruling 2016-0629511R3 - Post-Mortem Planning and Extraction of "Hard ACB" -- summary under Subsection 84(2)

B and Trust D&E will transfer their interests in various rental properties to Newco 3 under s. 85(1) for consideration including Class A common shares. ... A and Trust C will transfer their interests in rental properties to Newco 3 under s. 85(1) for consideration including Class A common shares. ... Trust C will transfer its Class A common shares of Newco 3 to Newco 1 under s. 85(1) in consideration for a non-interest-bearing demand promissory note equalling most of the Hard ACB of the transferred shares, and for Class C preferred shares of Newco 1 as to the balance. ...

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