Search - consideration
Results 1511 - 1520 of 28945 for consideration
Decision summary
Baytrust Holdings Ltd. v. IRC, [1971] 1 WLR 1333 (Ch D) -- summary under Subsection 132(6)
Firth transferred minority shareholdings in two companies ("British Acheson" and "High Speed") to it in consideration for treasury shares. ...
Decision summary
Edenvale Restoration Specialists Ltd. v. The Queen, 2013 BCCA 85 -- summary under Purchaser
.), sold tangible personal property to an Ontario limited partnership for consideration including units of the partnership representing 15% of the outstanding units, and only collected and remitted tax on 85% of the purchase price. ...
SCC (summary)
Falconer v. Minister of National Revenue, 62 DTC 1247, [1962] CTC 426, [1962] SCR 664 -- summary under Effective Date
However, an agreement evidencing the transfer and the consideration therefor (the obligation of Ponder to issue shares to the syndicate members) was not executed until September 25, 1951, by which date the assets had significantly increased in value. ...
Decision summary
Coates v. Arndale Properties Ltd., [1984] BTC 438 (HL) -- summary under Leases and Licences
The taxpayer (Arndale Properties) acquired the leasehold interest of SPI at a cost of £3,090,000 and, on the same day, assigned the leasehold asset to a third company in the group for consideration of £3,100,000. ...
FCA (summary)
McKesson Canada Corporation v. Canada, 2014 FCA 290 -- summary under Rule 75
The motions judge can also refuse amendment if the moving party has been dilatory, or considerations of fairness or prejudice so warrant (para. 10). ...
Decision summary
Barrick Gold Corporation v. Goldcorp Inc., 2011 ONSC 1325 -- summary under Solicitor-Client Privilege
Campbell J. stated (at para. 4): The documents make clear the particular input of a relatively small number of non-lawyer individuals outside the companies, whose input was necessary and appropriate to the consideration, structuring, planning and implementation of very complex transactions in a very short timeframe. ...
TCC (summary)
Royal Bank of Canada v. The Queen, [2007] GSTC 122, 2007 TCC 281 -- summary under Supply
In finding that such payments by RBC were the consideration for a taxable supply by CAIL of Points, Hershfield J stated (at para. 28): Everything CAIL did from being involved in establishing the terms of the credit facility to advertising the program was to promote the use of the card by the issuance of Points and that is what it was paid for – the issuance of Points. ...
TCC (summary)
McMullen v. The Queen, 2007 DTC 286, 2007 TCC 16 -- summary under Subsection 245(3)
The Queen, 2007 DTC 286, 2007 TCC 16-- summary under Subsection 245(3) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(3) The taxpayer and an unrelated individual ("DeBruyn") accomplished a split-up of the business of a corporation ("DEL") of which they were equal common shareholders by transactions under which (i) DeBruyn converted his (Class A) common shares into Class B common shares, (ii) the taxpayer sold his Class A common shares of DEL to a newly-incorporated holding company for DeBruyn's wife ("114") for a purchase price of $150,000, (iii) DEL issued a promissory note to 114 in satisfaction of a $150,000 dividend declared by it on the Class A shares, (iv) 114 as signed the promissory note to the taxpayer in satisfaction of the purchase price for the Class A shares, (v) the taxpayer transferred the promissory note owing to him by DEL to a holding company ("HHCI"), and HHCI purchased assets of the Kingston branch of the business of DEL in consideration for satisfaction of the promissory note. ...
TCC (summary)
McMullen v. The Queen, 2007 DTC 286, 2007 TCC 16 -- summary under Subsection 245(4)
The Queen, 2007 DTC 286, 2007 TCC 16-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) The taxpayer and an unrelated individual ("DeBruyn") accomplished a split-up of the business of a corporation ("DEL") of which they were equal common shareholders by transactions under which (i) DeBruyn converted his (Class A) common shares into Class B common shares, (ii) the taxpayer sold his Class A common shares of DEL to a newly-incorporated holding company for DeBruyn's wife ("114") for a purchase price of $150,000, (iii) DEL issued a promissory note to 114 in satisfaction of a $150,000 dividend declared by it on the Class A shares, (iv) 114 as signed the promissory note to the taxpayer in satisfaction of the purchase price for the Class A shares, (v) the taxpayer transferred the promissory note owing to him by DEL to a holding company ("HHCI"), and HHCI purchased assets of the Kingston branch of the business of DEL in consideration for satisfaction of the promissory note. ...
TCC (summary)
McMullen v. The Queen, 2007 DTC 286, 2007 TCC 16 -- summary under Paragraph 251(1)(c)
The Queen, 2007 DTC 286, 2007 TCC 16-- summary under Paragraph 251(1)(c) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) mutual benefit and same advisors insufficient to establish non-arm's length in structured sale transaction The taxpayer and an unrelated individual ("DeBruyn") accomplished a split-up of the business of a corporation ("DEL") of which they were equal common shareholders by transactions under which (i) DeBruyn converted his (Class A) common shares into Class B common shares, (ii) the taxpayer sold his Class A common shares of DEL to a newly-incorporated holding company for DeBruyn's wife ("114") for a purchase price of $150,000, (iii) DEL issued a promissory note to 114 in satisfaction of a $150,000 dividend declared by it on the Class A shares, (iv) 114 assigned the promissory note to the taxpayer in satisfaction of the purchase price for the Class A shares, (v) the taxpayer transferred the promissory note owing to him by DEL to a holding company ("HHCI"), and HHCI purchased assets of the Kingston branch of the business of DEL in consideration for satisfaction of the promissory note. ...