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La Reine, 2002 DTC 2065 (CCI) (ci-après "Ahmad"), le juge Miller qui avait à décider si les intérêts avant jugement reçus par un contribuable relativement à des dommages-intérêts étaient imposables, a statué comme suit sur le sens à donner au mot "intérêt": The starting point for the determination of the nature of an interest payment is the oft-cited definition of the Supreme Court of Canada in Re The Validity of Section 6 of the Farm Security Act, 1944 of the Province of Sasketchewan: Interest is, in general terms, the return or consideration or compensation for the use or retention by one person of a sum of money, belonging to, in a colloquial sense, or owed to, another... ...

The Preferred Shares of Newco which will be issued as described in paragraph 10 above, will not be, at any time during the implementation of the proposed transactions described herein: (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: A) 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 B) any right of the type described in subparagraph 112(2.4)(b)(ii). 19. ...

Although the reorganization was delayed due to a markedly increased level of activity with respect to Pubco's XXXXXXXXXX and financing activities, the Board of Directors of Pubco has now submitted the Proposed Transaction to Pubco's shareholders for consideration at the annual and special general meeting of shareholders which was held on XXXXXXXXXX. ...

XXXXXXXXX, B Co acquired, under an assignment agreement with A Co for consideration consisting of cash and a promissory note, all of A Co's interest in the Project. ...

In consideration for these services the Partnership pays the associates a per-diem amount or a negotiated fee-for-service. ...

In consideration for these services the Partnership pays the XXXXXXXXXX and associates a per-diem amount or a negotiated fee-for-service. ...

The Preferred Shares of Newco which will be issued as described in paragraph 10 above, will not be, at any time during the implementation of the proposed transactions described herein: (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: A) 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 B) any right of the type described in subparagraph 112(2.4)(b)(ii). 19. ...

If XCO elects under subsection 184(3) of the Act to avoid the Part III tax, the CRA would have to assess the shareholders of XCO in order to take into consideration the taxable dividend that would be deemed to be received by the shareholders under paragraph 184(3)(d) of the Act. ...

The Assigned Interest will become legally effective once the Fund and the Assigning Lender execute it, provide the required notice, obtain any necessary consent in accordance with the terms of the Credit Agreement and once the Fund pays the consideration and any required fees for the Assigned Interest. 7. ...

Lorsqu'il s'agit de distinguer les droits d'inscription à un programme sport-étude des frais d'activité parascolaire de nature sportive, il faut prendre en considération tous les faits pertinents. ...