Search - consideration

Noël J.A. stated at para. 33 that s. 10(1), which requires that inventory be valued at the lesser of cost or fair market value, overrides any GAAP considerations. ...

The consideration for the first five tranches was paid in cash, and for the last five tranches was paid by the issuance of an interest-bearing $20 million promissory note. ...

The consideration for the first five tranches was paid in cash, and for the last five tranches was paid by the issuance of an interest-bearing $20 million promissory note. ...

" In reaching this conclusion, the Court stated (at p. 6032): [A] gift is a voluntary transfer of property owned by a donor to a donee, in return for which no benefit or consideration flows to the donor. ...

., 2003 DTC 5471, 2002 FCA 422-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) asset strip to affiliate before tax motivated sale at loss In order to realize an allowable business investment loss on its investment in a corporation ("DMI") held jointly by it and a third party ("Rexfor"), the taxpayer and Rexfor formed a new corporation ("DMI 1993") owned jointly by them, arranged for DMI to transfer all its assets and liabilities to DMI 1993 save for two sawmills worth $2.5 million and $2.5 million of debt owing to a third party, and then sold the shares of DMI to an unrelated third party for nominal consideration. ...

The Queen, 2004 DTC 2909, 2004 TCC 474-- summary under Subsection 55(2) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2) transfer of safe income in a non-rollover transaction Each of the two individual taxpayers, who owned one-half of the shares of a Canadian-controlled private corporation ("Comcare") having an accrued gain of approximately $12.4 million and safe income of approximately $1.9 million, transferred his shares of Comcare to his own newly-incorporated holding company ("Holdco") in consideration for a promissory note and common shares of Holdco, thereby realizing a deemed dividend of approximately $10.4 million. ...

Expense- Contract or Option Cancellation payment for surrender of key lease was capital In finding that lump sums paid by a colliery company in order to secure a reduction in the scope of (in one case) or the cancellation (in the other case) of two mining leases (and thereby release its liability to restore the surface) were on capital account, Lawrence L.J. first noted (at p. 787) that the company's trade did not consist of acquiring mining leases and selling those mining leases but, rather, of the winning and selling of coal, and then stated (at p. 788): "... it cannot, in my opinion, reasonably be said that the consideration paid for and the acceptance of the surrender was a sum wholly and exclusively expended for the purpose of winning and selling the coal in which the Company traded. ...

The Queen, 93 DTC 965, [1993] 2 CTC 2658 (TCC)-- summary under Paragraph 12(1)(x) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x) inducement to purchase product for more was includible under s. 12(1)(x), or perhaps s. 9 The assumption by another corporation ("Polar Oils") of the obligation of the taxpayer to pay $119,658 in consideration for the taxpayer's agreement to pay four cents per litre more for diesel fuel purchased by it from Polar Oils until the total overpayments amounted to $119,658, constituted an inducement under s. 12(1)(x). ...

., 76 DTC 6010, [1976] CTC 24 (FCTD)-- summary under Paragraph 20(1)(n) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(n) The taxpayer, wished to sell land to the City of Calgary in consideration for two annual instalments in order to defer a portion of the gain to its second taxation year, but was informed that the City was precluded by statute from purchasing land over a period of years. ...

., 76 DTC 6010, [1976] CTC 24 (FCTD)-- summary under Subsection 246(1) Summary Under Tax Topics- Income Tax Act- Section 246- Subsection 246(1) The taxpayer, wished to sell land to the City of Calgary in consideration for two annual instalments in order to defer a portion of the gain to its second taxation year, but was informed that the City was precluded by statute from purchasing land over a period of years. ...