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In finding that all such amounts were fully deductible, Iacobucci J. indicated that he declined to follow Imperial Oil, 3 DTC 1090 (whose requirement that expenses need be incidental, in the sense that they were unavoidable, was based on the more restrictive statutory ancestor of s. 18(1)(a)), that making the deductibility of fines depend upon considerations of public policy would "place a high burden on the taxpayer who is to engage in this analysis in filling out his or her income tax return and would appear to undermine the objective of self-assessment underlying our tax system" (p. 5811), and that, in any event, denying deductibility might undercut one of the underlying premises of our tax system which "is that the state taxes only net, rather than gross, income because it is net income that measures a taxpayer's ability to pay". ...

He then stated (at para. 9): [T]he purpose of the present Application is not to challenge the validity of the Assessment but to remove the Decision that is an obstacle placed in Conoco's path towards a proper consideration by the Minister of its Objection. ...

As contemplated in the Offering Memorandum, two weeks later the partnership transferred its assets to the corporation in consideration for preferred shares, with the preferred shares then being distributed to the partners on the dissolution of the partnership. ...

., [1994] BTC 85 (HL)-- summary under Adjusted Cost Base Summary Under Tax Topics- Income Tax Act- Section 54- Adjusted Cost Base The following is a somewhat simplified description of transactions that would have occurred but for the withdrawal by Inland Revenue of an advance clearance: Investors purchased a leasehold interest in a property in a designated enterprise zone for 198 years from receiver-managers for the sum of £95 million, of which £64.125 million was borrowed on a 10-year full recourse and interest-bearing basis from a bank ("Hill Samuel"); the receiver-managers used £75.125 million of the amount received to pay a "reverse premium" to a subsidiary ("SQPL") of the promoter of the scheme ("Matrix") as the consideration for the previous agreement of SQPL to sublease the property for 99 years at a rent that, for the first 10 years of the sublease, was at an above-market rate; after payment of fees to Matrix and the funding of future construction costs, the receiver-managers retained £8 million of the £95 million received by them; SQPL lent £64.125 million to a subsidiary of Hill Samuel which, in turn, lent that sum to Hill Samuel; the balance of £8 million received by SQPL was used to pay a fee to Hill Samuel in respect of its guarantee of SQPL's obligations under the 99-year sublease, and to make a deposit with the subsidiary of Hill Samuel; rent for the initial 10 years under the 99-year sublease by SQPL was used to fund the interest payments owing by the investors on their loan from Hill Samuel; and an "exit arrangement" effectively permitted the investors after 10 years to cause the arrangement to be unwound at that time. ...

Around the time of launching the action, he and the two other directors entered into a "litigation agreement" with Disctronics which provided (para. 101): In consideration of [Disctronics'] promises [to pay all costs and disbursements] the directors…assign absolutely unto… [Disctronics], any award of damages (whether on revenue or capital account)… made in their favour as a consequence of their participation in the joint venture or arising out of the proceedings…. ...

Around the time of launching the action, he and the two other directors entered into a "litigation agreement" with Disctronics which provided (para. 101): In consideration of [Disctronics'] promises [to pay all costs and disbursements] the directors…assign absolutely unto… [Disctronics], any award of damages (whether on revenue or capital account)… made in their favour as a consequence of their participation in the joint venture or arising out of the proceedings…. ...

JC then transferred his shares of PC to a newly-incorporated holding company ("601") in consideration for a promissory note of 601 in the same amount and the issue of common shares. ...

The High Court held that each apartment lease, as an executory contract, obliged MBI to give Mirvac use and occupation of the apartment throughout the term of the lease in consideration for the periodic payment of rent, so that MBI's observance of this continuing obligation was properly characterized as an intended supply of residential premises by way of lease by it to Mirvac which was input taxed under s 40-35 of the Australian GST legislation. ...

Following a determination that the cement plant would be sold to an arm's length purchaser ("Lafarge") in transactions which sought to utilize the enhanced capital gains exemption, the following transactions were implemented: the taxpayer and the other shareholders of GH transferred a portion of their shares of GH to a newly-incorporated company ("Newco") in consideration for shares of Newco having a value of $500,000; GBC paid a dividend-in-kind of most of the cement plant assets (having a value of $1 million) to GH; GH redeemed the common shares held in its capital by Newco by transferring to Newco the assets which it had received from GBC; and the shareholders of Newco sold their interests in Newco to the Lafarge (who also purchased the remaining cement-plant assets directly from GBC). ...

The Queen, 2015 DTC 1141 [at at 908], 2015 TCC 146-- summary under Paragraph 12(1)(x) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x) amount subject to potential repayment obligation was not received General Motors of Canada Limited ("GMC") made "residual value support payments" to the taxpayer ("GMAC"), which purchased vehicles subject to leases, in consideration for GMAC increasing the residual values (thereby reducing lease payments). ...