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The distribution to the taxpayer was found to be part of the consideration for the contribution of property made by it to the partnership. ...

The Queen, 2000 DTC 6127 (FCTD)-- summary under Section 96 Summary Under Tax Topics- Income Tax Act- Section 96 A purported partnership ("Anwin") of which the taxpayer was a limited partner entered into a joint venture agreement with a corporation ("Anaquan") which was also the general partner of Anwin pursuant to which Anaquan agreed, in consideration for funding by Anwin, to incur qualifying research expenditures on the conduct of research at its facility in Winnipeg and to pay 10% of its gross income from the research facility, up to an annual maximum of 20% of the contract price, for the first five years of the agreement, and for the next five years to pay 5% of such gross income up to an annual maximum of 10%. ...

Although from CRA's perspective, what the casino was mostly getting paid for was its clerical services and the provision of the space, Sharlow JA found that the "commercial efficacy" of the whole arrangement turned on the provision of the cash by the casino, so that the fee was consideration for a single supply of a financial service under para. ...

Klink then transferred the computer to a recently-formed British Columbia limited partnership in consideration for a partnership interest therein. ...

Klink then transferred the computer to a recently-formed British Columbia limited partnership in consideration for a partnership interest therein. ...

The Queen, 97 DTC 1328 (TCC)-- summary under Safe-Income Determination Time Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(1)- Safe-Income Determination Time subsequent redemption of preferred shares was not assimilated to the series in which they were issued one or more year previously, given different objectives for each and lack of interdependence On September 10, 1988, the taxpayer transferred its assets to a subsidiary ("Alimentation 1988") in consideration for a demand promissory note and 506,125 Class B shares having a redemption value of $1 per share and nominal paid-up capital. 151,125 of the Class B shares were redeemed in the fiscal years of Alimentation 1988 ending on May 31, 1990, 1991 and 1992. ...

Klink then transferred the computer to a recently-formed British Columbia limited partnership in consideration for a partnership interest therein. ...

Klink then transferred the computer to a recently-formed British Columbia limited partnership in consideration for a partnership interest therein. ...

United Aircraft Corp. (1943), 7 A.T.D. 318 (HC)-- summary under Subparagraph 115(1)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 115- Subsection 115(1)- Paragraph 115(1)(a)- Subparagraph 115(1)(a)(ii) provision of knowhow in the US to Australian company not carrying on business in Australia An American manufacturer of airplanes purported to license its rights to use Australian patents and registered designs to an Australian company in consideration for a lump sum of $25,000 and further sums based on the number of aircraft engines manufactured by the Australian licensee. ...

., the taxpayer disposed of "a right to a right" of the sort described in what then was s. 66(15)(c)(ii)(B) when under a "farmout agreement" with Esso Resources Canada Limited, the taxpayer received from Esso the sum of $4.5 million in consideration for "... the right, licence and privilege of earning an interest in oil sands rights... ...