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The Queen, 2006 DTC 3401, 2006 TCC 440 (Informal Procedure)-- summary under Business Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Business The taxpayer let her neighbour's cattle graze on her pasture in consideration for a monthly fee per head, and agreed with her neighbour that he could crop-share her hay field. ...

Although it was often difficult to tell whether statements were based on legal or accounting considerations, Crampton CJ stated that he would "err on the side of caution" (para. 35). ...

The Queen, 2003 DTC 660, 2003 TCC 332-- summary under A Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Undepreciated Capital Cost- A A limited partnership purchased software from a vendor corporation in consideration for a cash payment and the issue by it of an "acquisition note". ...

In rejecting a submission that the money payable to High-Crest by the Department was not "government funding" as it was not for the purpose of making residential units in the facility available to seniors but, rather, was payable for the purpose of securing the services stipulated in the Service Agreement, Owen J stated (at para. 93): It is true that High-Crest was required to provide the Services as consideration for the payments it received from the Department. ...

It is the same consideration which makes it clear that the evidence of expert witnesses, that the L.I.F.O. method is a generally acceptable, and in this case the most appropriate, method of accountancy, is not conclusive of the question that the Court has to decide. ...

Expense- Restrictive Covenants Following competition among the major U.K. oil companies to have service stations distribute the companies' products on an exclusive basis, the taxpayer began entering into arrangements under which it would lease the service station from the owner for a period of up to 20 years in consideration for a nominal annual rent and a lump sum payment paid at the inception of the lease. ...

JS then transferred his shares of PC to a newly-incorporated holding company ("601") in consideration for a promissory note of 601 in the same amount and for the issue of common shares. ...

The Trial Judge had incorrectly found that the taxpayer had not made the payment referred to in (2) above, and the matter was referred back to the Minister for reconsideration of the third and fourth points above, together with consideration as to whether the claim by the taxpayer in his return for a business investment loss represented an election under s. 50(1). ...

After his common shares of Realwest had declined in value to $1,000, he (along with other investors in Realwest) transferred the shares of Realwest to a holding company in consideration for non-voting common shares of the holding company, thereby realizing an allowable business investment loss. ...

The Queen, 2001 DTC 243 (TCC)-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) The taxpayer, who owned a portion of the shares of the holding company ("GH") which, in turn, owned an operating company ("GBC") utilized the enhanced capital gains exemption in connection with the sale of a cement plant operated by GBC through the following transactions: the taxpayer and the other shareholders of GH transferred a portion of their shares of GH to a newly-incorporated company ("Newco") in consideration for shares of Newco having a value of $500,000; GBC paid a dividend-in-kind of most of the cement plant assets (having a value of $1 million) to GH; GH redeemed the common shares held in its capital by Newco by transferring to Newco the assets it had received from GBC; and the shareholders of Newco's sold their interests in Newco to the purchaser (who also purchased the remaining cement-plant assets directly from GBC). ...