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

Booth of Paradigm Capital, an expert in the valuation of reserves and resource estimates for the oil and gas industry, who concluded that the consideration contemplated by the arrangement was inadequate. ...

In his concurring reasons, Allsop CJ stated (at paras. 93-5) respecting the assimilated Art. 9 rule: [W]ere CAHPL seeking to borrow for five years on an unsecured basis with no financial or operational covenants from an independent lender, in order to act rationally and commercially and conformably with the interests of the Chevron group to obtain external funding at the lowest possible cost consistently with any relevant operational considerations, it would do so with Chevron providing a parent company guarantee, if such were available. ...

The taxpayer 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. ...

Canada, 2017 FCA 151-- summary under Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Supply service in relation to a cross-border vacation home portfolio split into two (GST-taxable and non-taxable) geographic components The Appellant, a Canadian-resident non-share corporation, most of whose members had time share points which entitled them to book stays at Canadian, U.S. and Mexican resort condos beneficially owned by the corporation, receiving its annual fees from them as consideration for funding the operating costs of the time share program. ...

In noting that broader considerations also supported a finding that the taxpayers’ shares were prescribed shares, he stated (at paras. 55-56, 58): The fact that the appellants were exposed to a risk from the moment when the options were granted and that the shares described under the terms of the plan were in all respects prescribed shares explain why they could have claimed the 50% deduction if they had simply sold their options to Cybectec…. ...

On December 7, 2007, the Limited Partnership transferred beneficial ownership of the rights to the pending permits (the “Purchased Applications and Purchased Permits”) to Devonian (while retaining legal title in trust for Devonian until the permits were granted) in consideration for Devonian agreeing to issue 999 shares. ...

At issue were Article 13 of the India-Denmark Double Taxation Agreement (the “DTA”), which permitted India to impose tax of 20% on the gross amount of fees for technical services (essentially defined as “consideration for the services of technical or other personnel”); and Article 9 of the DTA, which provided for a reduced rate of Indian tax on “profits derived from the operation of ships in international traffic.” ...

France (2017), No. 1505113/1-1 (Tribunal Administratif de Paris)-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 Google through its contracting arrangements with French advertisers avoided a French PE A French company (“Google France”) agreed pursuant to a Marketing and Services Agreement (the "Agreement") with a sister corporation (“Google Ireland”) to provide marketing assistance to Google Ireland in connection with the Google “AdWords”) program in France (under which French advertisers paid “per click” amounts for having their messages appear alongside related Google search results) in consideration for being reimbursed for its costs plus an 8% margin. ...

Lewski v Commissioner of Taxation, [2017] FCAFC 145-- summary under Incurring of Expense Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Incurring of Expense obligation to pay purchase price was incurred on agreement date rather than subsequent closing On June 30, 1999, a trust of which the taxpayer was a beneficiary had a 40% (later reduced to 2%) interest in a syndicate (that entered into an agreement to purchase an aged care facility in consideration for a “Settlement Amount” of $1.74 million to be paid on the settlement date (being the date of completion of a contemporaneous purchase of the business at the facility, slated to be October 31, 1999), with provision being made for further post-settlement amounts totalling $14.5 million. ...