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(footnote 3) However, based on our long standing position and the applicable jurisprudence (footnote 4), a rent normally refers to a payment (either periodic or a lump sum) that is consideration for the use or the right to use property for a term, whether fixed in time or otherwise determinable, after which the right of the grantee to the property and to its use reverts to the grantor. ...

Proposed subsections 248(30) to (32) of the Act allow for the recognition of a gift for tax purposes in certain situations where a donor, or a person or partnership who does not deal at arm's length with the donor, receives consideration or other advantages for property transferred. ...

X proposes to transfer the Subject Property, on an equitable basis, to each of Child A, Child B, Child C and Child D such that immediately thereafter each of Child A, Child B, Child C and Child D will own 1/4 of the Subject Property. 17) As sole consideration for the transfer of the Subject Property described in Paragraph 16, each of Child A, Child B, Child C and Child D, as the case may be, will provide a promissory note having a principal amount and FMV of $XXXXXXXXXX each. ...

X, in consideration for common shares of the capital stock of GesCo. Discretionary dividends are paid to GesCo. ...

" It does not appear that circumstances have changed and no similar case has come before the courts for their consideration since that time. ...

The Note was issued in XXXXXXXXXX to Foreign LP by an arm's length party in consideration for the sale of land owned by Foreign LP. ...

Dès lors que l’activité du contribuable comporte un aspect personnel, il est essentiel de prendre en considération tous les faits entourant l’activité du contribuable afin de déterminer si elle est exploitée de manière suffisamment commerciale. ...

None of the issued preferred shares will at any time during the implementation of the proposed transactions be: (a) subject to any secured undertaking of the type described in paragraph 112(2.4)(a) of the Act; or (b) issued for a consideration that includes: (i) an obligation of the type described in subparagraph 112(2.4)(b)(i) of the Act, other than an obligation of a corporation that is related (otherwise than by reason of a right referred to in paragraph 251(5)(b) of the Act); or (ii) any right of the type described in subparagraph 112(2.4)(b)(ii) of the Act. 19. ...

Throughout this advance income tax ruling, the singular should be read as plural and vice versa where the circumstances so require: (a) “Employee” means the employee of ForCo, more fully described in paragraph 9 below; (b) “Employment Agreement” means the agreement entered into by and between Employee and ForCo on XXXXXXXXXX which establishes the employee/employer relationship between them; (c) “ForCo” means XXXXXXXXXX, a corporation more fully described in paragraph 4 below; (d) “Foreign Parent” means XXXXXXXXXX, a corporation more fully described in paragraph 1 below; (e) “Master Agreement” means the agreement entered into by and between Foreign Parent and a Member, more fully described in paragraph 2 below; (f) “Member” means a corporation or other type of entity that has entered into a Master Agreement with Foreign Parent; (g) “Proposed Transactions” means the transactions described in paragraphs 11 to 14 below; (h) “Service Contract” means the contract entered into by and between Foreign Parent and ForCo on XXXXXXXXXX for the provision of services in Canada by ForCo in respect of the Canadian Members of Foreign Parent, more fully described in paragraph 6 below; (i) “Service Fee” means the fees payable by Foreign Parent to ForCo as consideration for services rendered by ForCo under the Service Contract; and (j) “Treaty” means the Canada-U.S. ...

The Lossco Series III Preferred Shares will not at any time during the implementation of the Proposed Transactions be: (a) the subject of any undertaking that is referred to in subsection 112(2.2) as a “guarantee agreement”; (b) the subject of a dividend rental arrangement; (c) the subject of any secured undertaking of the type described in paragraph 112(2.4)(a); or (d) issued for consideration that is or includes: (i) an obligation of the type described in subparagraph 112(2.4)(b)(i), other than an obligation of a corporation that is related (otherwise than by reason of a right referred to in paragraph 251(5)(b)); or (ii) any right of the type described in subparagraph 112(2.4)(b)(ii). 33. ...