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The Queen, 2007 DTC 286, 2007 TCC 16-- summary under Subsection 84(2) Summary Under Tax Topics- Income Tax Act- Section 84- Subsection 84(2) 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. ...

The Queen, 2007 DTC 286, 2007 TCC 16-- summary under Subsection 84.1(1) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(1) arm's length: negotiation based on self-interest 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. ...

In finding that the taxpayer was deriving his remuneration from a contract for services notwithstanding that he worked for various projects at Canadair for a five-year period, the court accepted evidence that "the Appellant in consideration for a higher pay gave up many of the benefits which usually accrue to an employee including job security" (p. 6871- per Noël J.A.) and stated (p. 6870- per Décary J.A.): "When the hiring person wants to have no liability towards a worker other than the price of work and when the terms of the contract and his performance reflect those intentions, the contract should generally be characterized as a contract for services. ...

The Queen, 2015 DTC 1103 [at at 614], 2015 TCC 80 (Informal Procedure)-- summary under Effective Date Summary Under Tax Topics- General Concepts- Effective Date consideration for transfer to shareholder adjusted without price adjustment clause An individual shareholder of a corporation ("B&N") thought that he was the beneficial owner of his home, but everyone else, including his accountants (and ultimately the Tax Court) considered that it was beneficially owned by B&N. ...

The definition of a capital beneficiary included individuals (subject to specified exclusions) had made written application to the Trustee for consideration for inclusion as a Capital Beneficiary, had made charitable donations to one or more registered charities in the calendar year of such application and received receipts in prescribed form for such donations. ...

The next day, the taxpayer sold these shares to a partnership of which his wife was a general partner and three of his children held a 99% limited partnership interest in consideration for a $487,000 promissory note of the partnership bearing interest at the rate prescribed for purposes of s. 74.5. ...

-resident corporative association of dairy companies, received a fee from a Canadian member that was, in part, a royalty for the use in Canada of a certification mark and, in part, consideration for know-how provided by it to the Canadian member, namely, providing assistance on production, quality control, advertising and marketing. ...

Repairs or Running Expense perimeter road construction for promotion A large lump sum payment was made by the taxpayer to the City of Calgary in consideration of (i) the City improving the system of roads around the taxpayer's shopping centre and (ii) an implied promise of the City not to assess the taxpayer for local improvement taxes in respect of the cost of such improvements. ...

In consideration, the advertiser was to pay the newspaper's advertising fees in each month that those fees arose, and at the end of the twelve-month period to pay $1000 minus all the advertising fees spent in that period (or nothing at all if the fees exceeded $1000). ...

. … The words of the Act require consideration of a transaction in its entirety and it is not open to the Crown artificially to split off various aspects of it in order to create an avoidance transaction. ...