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Results 6161 - 6170 of 28966 for consideration
TCC
Gascho Farms Ltd. v. The Queen, 97 DTC 808, [1997] 1 CTC 2092 (TCC)
As consideration for the sale of the Assets, the purchaser gave back a first mortgage in the amount of $212,000.00, paid the sum of $150,000.00, subject to the usual adjustments, by certified cheque and conveyed the purchaser’s property located at 412 Carene Court, Waterloo, Ontario, hereinafter called “the Property”, to the Appellant. ... Moreover, if one were to add a reasonable figure for repairs and maintenance, it is highly unlikely that a profit could have been realized not even taking into consideration capital cost allowance. ...
TCC
Ronald Michael Kornelow v. Minister of National Revenue, 91 DTC 431, [1991] 1 CTC 2403 (TCC)
Some of these show that these transactions occurred in the chronological order indicated: on June 30, 1978, in consideration of the Bank of Montreal dealing with K & L, the appellant and his wife guaranteed K & L debts and liabilities up to $35,000; on July 26,1979, K & L executed a promissory note in favour of the Bank of Montreal in the sum of $35,000; on September 18, 1978, K & L entered into a security agreement with the Bank of Montreal whereby as security for the payment of existing and future indebtedness it granted to the bank a security interest in its existing and future assets; on September 20, 1978, in consideration of the Bank of Montreal dealing with K & L, the appellant and his wife guaranteed K & L debts and liabilities up to $15,000; on July 17, 1978, Eileen Nolan, the mother-in-law of the appellant, borrowed $40,000 from the Royal Trust Corporation of Canada which was secured by a mortgage on her home and the appellant guaranteed the repayment of the money secured by the mortgage and in February 1986 the appellant and his wife borrowed $65,000 from the Guaranty Trust Company and this loan was secured by a mortgage on their home. ...
FCTD
Canada Forgings Ltd. v. The Queen, 83 DTC 5110, [1983] CTC 94 (FCTD)
In consideration therefor Canada Forgings paid to each of them the sum of $325,000. ... This is made clear in paragraph 7A of the takeover bid circular which Toromont sent out to all shareholders (page 98) wherein it is stated: In addition Toromont and Messrs Fraser and Peacock have agreed that Messrs Fraser and Peacock will surrender their options to purchase 50,000 common shares for a consideration equal to $17.00 per share less the exercise price of the option. ...
FCA
Canada v. Doubinin, 2005 DTC 5624, 2005 FCA 298
The Tax Court Judge said "It was a genuine gift and not given with the expectation of a receiving a material benefit or any other type of consideration from PPF. ... Friedberg, 92 DTC 6031 (FCA), and specifically the quote from the reasons of Linden J.A. on what constitutes a gift as follows: a voluntary transfer of property owned by a donor to a donee, in return for which no benefit or consideration flows to the donor (see Heald, J. in The Queen v. ...
FCA
Le Soleil Limitée v. MNR, 73 DTC 5093, [1973] CTC 91 (FCA)
As such a person, for a consideration, it agreed to put an advertisement on behalf of the advertiser in its (the appellant’s) newspaper so that, when a member of the public got the newspaper, the advertiser’s message would, it might be hoped, be communicated to him. ... However, in this Court, another view of the matter was put forward, which, counsel for the Minister agrees, is open for consideration in this Court on the basis on which the trial was conducted in the Trial Division. ...
T Rev B decision
Westcon Engineering and Contractors Ltd. v. MNR, 77 DTC 284, [1977] CTC 2387 (T.R.B.)
The aircraft was sold for a consideration of $19,900.00, and the aircraft was acquired by the company in terms of the capital purchase in the amount of $12,408.11. ... Giving the matter my best consideration on the basis of the evidence before the Board, including the exhibits filed, I must conclude that the appellant has not met the onus of proof that the Income Tax Act places on it in situations of this kind and the appeal on this issue is also dismissed. ...
FCA
Plomberie J.C. Langlois inc. v. Canada, 2007 DTC 5662, 2006 FCA 113
Simoneau had the dominant role as a sole director without taking into consideration the unanimous shareholder agreement signed by the two shareholders (Duha Printers (Western) Ltd. v. ... According to the appellant, the judge of the Tax Court of Canada erred in law, because she reached this conclusion without taking this agreement into consideration. ...
TCC
A.C. Simmonds & Sons Ltd. v. MNR, 89 DTC 707, [1990] 1 CTC 2087 (TCC)
The word implies the existence of a debtor, legality of the obligation, the existence of a consideration, and execution or performance by the creditor. ... This is not, in my opinion, descriptive of the transactions involving letters of credit that are under consideration in this appeal. ...
FCA
Bendix Automotive of Canada Ltd. v. The Queen, 78 DTC 6137, [1978] CTC 194 (FCA)
As I appreciate it, there were two main branches of evidence to be considered, viz: (a) the market history of the value of the shares that were held by persons other than the appellant in the third company; and (b) the consideration received for the block of shares constituting the dividend by the parent company from a purchaser with whom it was dealing at arm’s length immediately after the payment of the dividend. As I understand the facts, either the learned trial judge put to himself the wrong question or he was clearly wrong in concluding that the evidence of the market value of the minority shares (influenced as it seems to have been by the exchange offer that arose out of the negotiations between the purchaser and the parent company) outweighed the evidence of the value of the consideration negotiated with an arm’s length third person for the block of shares constituting the dividend at the relevant time. ...
FCTD
The Queen v. McLaughlin, 78 DTC 6406, [1978] CTC 602 (FCTD)
A biography of each individual recommended and a summary of the contribution made by him are submitted for consideration. ... In my view, the award received by the defendant taxpayer from the H R MacMillan Trust for his achievements in agriculture was in the nature of a gift, ie a transfer of property from one to another gratuitously with no valuable and legal consideration whatsoever being in- volved. ...