Search - consideration

He further found that charges made by DTI at the end of each trip to the drivers of $0.76 per mile for fuel, and $0.08 per mile for vehicular maintenance, were consideration for an on-supply by DTI to the drivers of fuel and maintenance services. ...

The Queen, 2020 TCC 53-- summary under Subsection 232(3) Summary Under Tax Topics- Excise Tax Act- Section 232- Subsection 232(3) failure to credit the adjustment precluded a s. 232(3) deduction In 2012, a company (“9267”) sold domain names to another corporation (“9210”) that was owned equally by its individual shareholder and an unrelated individual for cash consideration to be paid in instalments. ...

A court should give significant consideration to amendments which further the ability of the trial court to determine the questions in controversy …. ...

The consideration paid included a promissory note for $190,000 with a five-year term and bearing interest at 7.5%. ...

The Queen, 2022 TCC 13-- summary under Subsection 104(6) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(6) s. 104(6) permitted the deduction of an amount initially treated as a capital distribution An estate engaged in accelerated pipeline transactions in which it transferred shares (stepped up under s. 70(5)) of a portfolio company (“Holdco”) to a Newco in consideration for a note, with Holdco being wound up into Newco a day later – and with the note being repaid by Newco to the estate about three weeks later. ...

The reason for the mistake is simply not a consideration in the application of the section. ...

This reporting was accepted by the Court of Quebec on the basis inter alia that the equivalent of ITA s. 7(3)(a) established that the stock option rules constituted a “complete code” so that the equivalent to ITA s. 69(1)(b) did not apply to deem the “value of the consideration for the disposition” received by the taxpayer to be equal to the options’ fair market value of $3M, rather than the nil proceeds in fact received. ...

The King, 2023 TCC 67 (Informal Procedure)-- summary under Recipient Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Recipient the recipients of a supply were the agents named in the purchase agreement, not the beneficial purchaser A claimant of the new residential rental property rebate (NRRPR) is required under s. 256.2(3)(a) to be the “recipient” of the supply of the property meaning, generally, that it is liable for the consideration for the supply under the purchase agreement. ...

Lanery, were employee remuneration for CPP and EI purposes turned on a determination of their “dominant purpose,” namely, “whether on balance the payments were made on account of monetary assistance to enhance the PDF’s education and research skills or paid as income in consideration of various services provided by the PDF to the University.” ...

Lanery) were employee remuneration for CPP and EI purposes turned on a determination of their “dominant purpose,” namely, “whether on balance the payments were made on account of monetary assistance to enhance the PDF’s education and research skills or paid as income in consideration of various services provided by the PDF to the University.” ...