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He concluded (at para. 38) that "the system of submission of claims does not constitute an ‘invoice'…[and] the moment when the consideration for the taxable supply becomes due is the moment when the manufacturer approves the claim. ...

Thorn EMI plc, [1987] DTC 462 (CA)-- summary under Property Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Property A lump sum which the taxpayer (a British holding company) received as consideration for a non-competition agreement given by it to the U.S. purchaser of three operating companies indirectly owned by it was found to be a capital gain pursuant to s. 22(3) of the Finance Act 1965 which provided that: "There is... a disposal of assets by their owner where any capital sum is derived from assets notwithstanding that no asset is acquired by the person paying the capital sum.... ...

The Queen, 2004 DTC 2604, 2004 TCC 280, briefly aff'd 2006 DTC 6351, 2006 FCA 171-- summary under A Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Undepreciated Capital Cost- A A partnership acquired Canadian rights to software in consideration for $960,000 in cash and an acquisition note in the amount of $12.15 million under which the interest was capitalized for the first nine years and thereafter quarterly instalments became due. ...

MNR, 96 DTC 1094, [1996] 1 CTC 2218 (TCC)-- summary under Paragraph 18(1)(e) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(e) The taxpayer, which ran a funeral home business and agreed with many of its customers to provide the required funeral services on each customer's death in consideration for a lump sum paid by the customer at or shortly after entering into the contract, also entered into a contract with the Fiducie du Quebec (the "Trustee") under which it was agreed that the Trustee would credit all sums of money delivered to it into a capital account, and credit 40% of all income earned on the capital account and a reserve account into that reserve account. ...

The trademarks were acquired by NN Life on the same day as the sale to the appellant and NN Life gave consideration to Underwriters equivalent in value to what it received from the appellant. ...

The Queen, 94 DTC 1858, [1995] 1 CTC 2135 (TCC), aff'd at 98 DTC 6501 (SCC) after being, rev'd 96 DTC 6355 (FCA)-- summary under Agency Summary Under Tax Topics- General Concepts- Agency compelling evidence required to consider one company as agent for another The taxpayer's subsidiary ("CBL") transferred leasing assets to a partnership between CBL and two subsidiaries of a third party that was interested in acquiring those assets ("CCM" and "693396") in consideration for a partnership interest, an election was filed under s. 97(2), the taxpayer acquired the partnership interest of CBL on a winding-up of CBL pursuant to s. 88(1) and the taxpayer sold the partnership interest to 693396 and an affiliate of 693396. ...

., in his concurring reasons, found that the vendors were able to deduct $800,000 as an outlay or expense of the disposition (pp. 6413-6414): "In my opinion it is not necessary for a payment to be made without any consideration for there to be a 'débours' or 'outlay'... ...

Olsen, 2002 DTC 6770, 2002 FCA 3-- summary under Subsection 84.1(1) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(1) reference to s. 186(4) test included related definition The taxpayer transferred shares of a corporation ("Leader") to corporations controlled by the taxpayer's children and spouses in consideration for promissory notes. ...

Remai, 2009 DTC 5188 [at at 6257], 2009 FCA 340-- summary under Paragraph 251(1)(c) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) providing a favour is consistent with arm's length dealing In order to make promissory notes that he had donated to a charitable foundation cease to be non-qualifying securities, the taxpayer arranged for the Foundation to sell those promissory notes to a corporation ("Sweet") owned as to 90% by his nephew, with Sweet issuing notes with identical terms to the Foundation as consideration for the purchase. ...

However, in my opinion, it more accurately reflects reality to say that Fiducie transferred 433 shares whose unit market value was $6,550, that the actual selling price of those shares was $2,836,423 (433 × $6550), an amount which, in fact, 404 obtained when it resold the shares to Keolis, and that the consideration given for this market value of $2,836,423 included two elements: a $2,602,637 promissory note, and 404's agreement to pay fees that Fiducie would have had to pay if 404 had not been interposed in the series of transactions carried out to sell the shares in question to Keolis. ...