Search - consideration

Spiro J referred to the taxpayer’s experience in the real estate area, and stated (at para. 79): The Appellant knew or ought to have known that acquiring more than $2.4 million of corporate property from HGSL for no consideration was a shareholder benefit. ...

As soon as LBL delivered the products to the store vicinity, and it received the cash consideration, the products were loaded onto the waiting trucks of customers, in turn, of Roberta MacNaughton. ...

Canada, 2024 FCA 3-- summary under Property Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Property break fee was not consideration for the disposition of a merger right as there was no such “right” An integrated nickel-mining public company (“Falconbridge”), entered into merger agreements with a more junior public company (“Diamond Fields”) which, through a 75%-owned subsidiary, held a valuable deposit at Voisey’s Bay in Newfoundland. ...

Agence du revenu du Québec, 2023 QCCQ 10241-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership property was transferred to shareholders as nominees in light inter alia of consistent reporting of the transferor as the continued actual owner The ARQ assessed the appellant (9154-6093) for its failure to collect and remit QST on its transfer of a condo unit (Unit 54) to its shareholders (two spouses) in April 2009 for consideration of $567,000. ...

Agence du revenu du Québec, 2023 QCCQ 10241-- summary under Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Supply the ARQ contravened its role by assessing a taxpayer for QST on a property transfer while continuing to collect QST as if the taxpayer was still owner The ARQ assessed the appellant (9154-6093) for its failure to collect and remit QST on its transfer of a condo unit to the couple who were its shareholders for stated consideration. ...

To give effect to the [contrary] contention on behalf of the Minister, it would seem necessary to make an investigation of the clientele who patronized the business and of the proximity of the former business where the loss was incurred to the premises occupied in the operation of a business where profits were realized before permitting the loss to be deductible under the said paragraph (p), and I cannot reach the conclusion that any such consideration was present in the mind of Parliament when the legislation was enacted. ...

Furthermore, “there [was] not sufficient evidence to determine an amount of consideration to purchase intellectual property, nor the tax paid or payable” (para. 44). ...

Canada, 2025 FCA 20-- summary under Subsection 248(10) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(10) series of transactions included the subsequent loss utilization which motivated corporate restart transactions Under a “restart” plan, the appellant changed its name, spun out its existing mining assets so that it was a shell with only tax losses, and B.C. real estate companies of two individuals (Grippo and Heung) transferred various real estate assets, including jointly owned properties, to the appellant for consideration that included shares of the appellant. ...

Canada (the King), 2025 FCA 27-- summary under Specified Provincial Input Tax Credit Summary Under Tax Topics- Excise Tax Act- Section 236.01- Subsection 236.01(1)- Specified Provincial Input Tax Credit Ontario electricity suppliers made single supplies of electricity notwithstanding separate regulatory and delivery charges, so that there were full RITCs Bell Canada was required as a result of ETA s. 236.01 and the related regulation to recapture 100% of the input tax credits that it claimed in respect of the 8% Ontario HST that it paid on the consideration for the supplies to it in Ontario of electricity. ...

The King, 2023 TCC 45, aff'd 2025 FCA 27-- summary under Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Supply Bell Canada received single supplies of electricity from its Ontario electricity suppliers Bell Canada was required as a result of ETA s. 236.01 and the related regulation to recapture 100% of the input tax credits that it claimed in respect of the 8% Ontario HST that it paid on the consideration for the supplies to it in Ontario of electricity. ...