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Pallota J also rejected the Crown’s position that Zeifmans’ position in this application represented an impermissible collateral attack on the prior administrative order (the requirement) given that inter alia the imposition of separate conditions under s. 231.7(1)(a) notwithstanding that a recipient of a requirement could apply for judicial review of the requirement “indicate[d] Parliament did not intend for judicial review to be the sole forum for considering whether the Minister properly exercised her authority in issuing the Requirement” (para. 66), the two proceedings had a different character (of a reasonableness review, contrasted to a substantive review of whether the s. 231.7 considerations were satisfied – see paras. 74, 81-82), and in the earlier proceeding, the Minister had failed to disclose that the Unnamed Persons in fact were being targeted. ...

If paragraph (a) did not apply, it is my view that paragraph (b) of the definition of “recipient” would apply in the alternative because it is my view …the MacNaughtons were liable to pay the consideration for the purchase of the Tobacco Products.... ...

Since the Tax Court had not considered the evidence relating to this point, the matter was referred back to the Tax Court for such consideration. ...

.$86 million to the respondent, effectively in consideration for secured debt and preferred shares, thereby reducing the equity interest of the five arm’s length holders of 51% of the MMV voting common shares to less than 0.01% and also permitting the use of the respondent’s non-capital losses. ...

.$86 million to the respondent, effectively in consideration for secured debt and preferred shares, thereby reducing the equity interest of the five arm’s length holders of 51% of the MMV voting common shares to less than 0.01% and also permitting the use of the respondent’s non-capital losses. ...

Now that MPP was an empty shell, Madison and Vanac transferred respective portfolios of rental properties to MPP in consideration for the assumption of liabilities and for the issuance of a mixture of Class B voting shares and Class C non-voting shares (with the same attributes other than being generally non-voting) so that Madison and Vanac collectively held (and in equal proportions, after giving effect to some catch-up transactions to equalize those holdings) 46.6% of the voting rights and 92.8% of the equity of MPP. ...

Corco purchased all of the appellant’s shares in consideration for issuing a $600,000 demand promissory note. ...

.$73 million (with the balance of the company sold two years later for US$63 million), the dominant shareholder of the company (James) engaged in estate freeze transactions and caused common shares representing 15% of all the common shares to be issued for nominal consideration to a trust for the benefit of present and future employees. ...

.$73 million, an estate freeze was implemented by its dominant individual shareholder, and a 15% common shareholding was issued for nominal consideration to a trust for the benefit of present and future employees. ...

This was accomplished by transferring their co-ownership interests on a s. 85(1) rollover basis to respective Newcos (“HP Newco”, in the case of Harvard Properties) in consideration inter alia for voting and non-voting shares, followed by a sale of those voting shares to an Abacus subsidiary (NH Properties) for promissory notes for under half of the sale price. ...