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Accordingly, she affirmed the Minister's assessment, which was made on the basis that the provision by Marriott of franchise rights was an "imported taxable supply" under s. 217, for which the registrant was liable to pay GST on the consideration paid on the basis that 30% of the franchise fees was not eligible for an input tax credit. ...

Accordingly, she affirmed the Minister's assessment, which was made on the basis that the provision by Marriott of franchise rights was an "imported taxable supply" under s. 217, for which the registrant was liable to pay GST on the consideration paid on the basis that 30% of the franchise fees was not eligible for an input tax credit. ...

Accordingly, the "consideration" received by the taxpayer for the supply was the full price, rather than 80% thereof. ...

Re Euro Hotel (Belgravia) Ltd. (1975), 51 TC 293 (Ch D)-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) The taxpayer, which was entitled to a long lease of land in consideration of developing the land, assigned its ultimate rights to the lands to a bank, which paid £1,500,000 to the taxpayer and was required to grant a long underlease of the lands to the taxpayer at a rack rent upon completion and in the mean time to make payments (which the taxpayer was not obligated to repay), to the taxpayer to finance development of the lands. ...

It agreed to accept a surrender of the lease to Farb in consideration for the payment to it of $17,000 by an oil company ("Imperial Oil"), and leased the portion of the property used for the service station to Imperial Oil, which subleased its interest to Farb at the same rent. ...

After noting that the factors which may be taken into consideration by a taxpayer in claiming a bad debts deduction are the aging and history of the account, the financial position of the client, the past experience of the taxpayer with the writing-off of his bad debts, general business conditions, and increases or decreases in total sales and accounts receivable at the end of the year, Mr. ...

The Queen, 2008 DTC 482, 2008 TCC 255-- summary under Shares Summary Under Tax Topics- General Concepts- Fair Market Value- Shares In the context of estate freeze transactions, a trust that the taxpayer had established for the benefit of his children transferred a portion of the Class A shares of a corporation that was controlled by him ("335") to his son's holding company ("2165") in consideration for shares of 2165. ...

The Queen, 2008 DTC 482, 2008 TCC 255-- summary under Subsection 56(2) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(2) In the context of estate freeze transactions, a trust that the taxpayer had established for the benefit of his children transferred a portion of the Class A shares of a corporation that was controlled by him ("335") to his son's holding company ("2165") in consideration for shares of 2165. ...

The Queen, 2014 DTC 1162 [at at 3556], 2014 TCC 30-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) revenues 10% of interest On December 31, 1993, the taxpayer and other parties to a joint venture acquired rights to exploit seismic data in consideration for $975,000 cash and a $5,525,000 promissory note (payable only out of 50% of net licensing revenues and 20% of any production cash flow generated out of any petroleum rights acquired by the joint venture)- which the Minister conceded was not a contingent liability. ...

Gitman, in consideration for an annual fee of $150,000. The partnership was its only client. ...