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Immediately before the closing of the sale to MDPC, the taxpayer exchanged all his commons shares of MDPC under s. 86 for preferred shares with a redemption value of $2 million and for new common shares of MDPC, and then immediately sold 85% of those common shares equally to his wife and two children for nominal consideration. ...

In July 2013, the husband transferred his ½ co-ownership interest (the “Interest”), in a real estate property that they co-owned, to her for no stated consideration. ...

He added (at para. 21): [W]here gross negligence is alleged, I would expect consideration of whether the conduct of the taxpayer at issue is such a marked departure from what would be expected that it constitutes a high degree of negligence sufficient to be characterized as a marked departure from the standards, practices, and due diligence expected of a responsible taxpayer. ...

The Queen, 2018 TCC 113-- summary under Subpargraph 12(1)(x)(viii) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x)- Subpargraph 12(1)(x)(viii) an early signing bonus was part of the proceeds of disposition of the subject property The taxpayer, who rented his farm to a corporation controlled by him, received an early “signing bonus” of $255,790 from Enbridge for entering into an agreement with Enbridge by the stipulated deadline under which he granted an easement for a pipeline to Enbridge for additional stipulated consideration and damages. ...

He further quoted approvingly (at para. 13) the statement in Jones that “similar considerations should apply to recreational activities.” ...

After finding that a settlement agreement had been reached (given the parties’ mutual intention to create legal relations, the flowing of consideration, sufficiently clear terms, and a matching on all essential terms), Lyons J went on to note (at para. 62) that: University Hill … reaffirmed the principles in Galway and CIBC and commented that settling the quantum of expenses is not an all or nothing function and involved a compromise of facts, therefore, “the Court will only interfere if the agreed‑upon facts clearly have no bearing to reality.” ...

In consideration, they were permitted to keep the recoveries of alternative minimum tax made by them in the subsequent taxation years. ...

Colitto) for nominal consideration. In 2016, CRA assessed Ms. Colitto on the basis that Mr. ...

This last consideration regarding time spent in each location is very important and must be given great weight. … [T]he Appellant and her husband may retire approximately two years after the hearing of this matter. ...

Canada, 2019 FCA 306-- summary under Subsection 55(2) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2) s. 55(2) operated through denying a s. 53(1)(b) ACB bump An individual rolled his apartment building into a Newco in consideration for a mortgage assumption and shares with nominal paid-up capital, and then rolled those shares into a new Holdco. ...