Search - consideration

The funds are ultimately derived as consideration for the employee’s services, and on that basis they are properly to be considered emoluments or earnings. ...

Gendron") in consideration for a promissory note (payable in five annual instalments) and elected that s. 73 not apply to produce rollover treatment. ...

Richards in consideration for Ms. Richards’ guarantee – and as not resulting in any interest in the condo also being supplied by the builder to Ms. ...

Concerning the intention of Ronald or Soutar Décor as to timing, actions or effect, section 160 is clear: intention is of no import beyond gauging the adequacy of consideration: Wannan v. ...

After noting (at para. 77) that his decision was limited to the question as to whether there was any s. 39(2) gain and after noting that the debenture indenture provided that the converting holder was entitled to cash equal to the current market value of any fractional share and that the directors’ resolution issuing the shares on conversion essentially indicated that the fair value of the consideration received for the shares’ issuance was their “Sale Price” (i.e., current market price on the NYSE), Ryer JA stated (at paras.103-104): [T]he Repayment Amount in respect of each Convertible Debenture was, in essence, the US$ amount determined when the “Sale Price” of a Common Share, on each Conversion Date…was multiplied by 71.429. ...

ARQ, 2016 QCCS 2158, aff'd 2016 QCCA 1303-- summary under Subsection 240(1.1) Summary Under Tax Topics- Excise Tax Act- Section 240- Subsection 240(1.1) Uber drivers, as operators of “taxi” businesses, likely were required to register for QST The ARQ obtained a search warrant for searching an Uber Canada office in Montreal, which under s. 40 of the Tax Administration Act (Quebec), required that the ARQ employee laying the information have reasonable grounds to believe that Uber Canada was committing an offence, on the grounds that (1) Uber Canada (which was registered for QST purposes) was making false returns by not treating the per-drive commissions of 20% which it earned from its Quebec drivers as being consideration for taxable supplies, and (2) it was aiding the drivers in committing the offence of wilfully evading the collection of QST by virtue of its system for collecting the customer fares (through the customers’ credit cards) not treating those fares as being subject to QST (or GST). ...

Turgeon) agreed to sell some preferred shares of the CCPC to a newly formed Holdco of its controller (“Hélie Holdco”) in consideration for a promissory note bearing interest at 4% and which was to be repaid over a number of years out of dividends or redemption proceeds received by Hélie Holdco from the CCPC. ...

In rejecting the Crown’s argument that the test in s. 104(2)(b) (of the multiple trusts being “conditioned so that the income thereof accrues or will ultimately accrue to the same beneficiary or group or class of beneficiaries”) must be applied on an annual basis, he stated (at paras 14, 15, 16 and 21): …[T]he text of paragraph 104(2)(b) appears to contemplate a consideration of the right to receive the income of the trust over the entire lifetime of the trust rather than for each taxation year. ...

The evidence demonstrates that the sale subject to the assessment was justified on the basis of personal and family considerations of Mr. ...

Stock ‘94 Szolgáltató Zrt. v Regional Customs and Finance Directorate-General for Southern Transdanubia of the National Tax and Customs Office, Hungary, [2016] BVC 45, C-208/15 (European Court of Justice (5th Chamber))-- summary under Paragraph (f) Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Financial Service- Paragraph (f) interest on a loan funding a taxable supply of goods was part of the consideration for a single supply of the goods Stock ‘94 was a company which acted as an “integrator,” i.e., it assisted Hungarian farmers (“integrated producers”) by making a loan to the farmer, which was used to purchase current assets for use on the farm. ...