Search - consideration

Similar principles apply where the taxpayer lends money to speculative start-up companies with a view to profiting from the resale of shares of the companies which are issued to the taxpayer for nominal consideration, so that the loans (in addition to the shares) may be acquired by the taxpayer on income account (Freud, Greenberg, see also Hayter). ...

Reorganization transactions Consistently with reorganization transactions involving other types of property (see Hickman Motors), it has been found that the acquisition of a partnership interest from an affiliated person in a reorganization transaction, followed by an immediate sale of the partnership interest for consideration presumably equal to its fair market value at the time of such acquisition, is not a trading transaction (i.e., not a transaction that would motivate a trader)- so that the sale occurs on capital account (Continental Bank). ...

First, a general partner distribution, which otherwise might be deemed by draft s. 272.1(8) (when read in conjunction with s. 272.1(3)) to be consideration for a taxable supply of management or administrative services, as well as any separate fee by it or an affiliated Canadian corporation for management or administrative services could qualify as a zero-rated supply under Sched. ... As a qualifying taxpayer, it would be subject to a requirement to self-assess GST under s. 218.01(b) on its “qualifying consideration” for the year (as defined in s. 217, and assuming that it had not made an election under s. 217.2(1) to be subject to tax on its internal and external charges for the year), so that it potentially would be subject to GST on its deductible outlays or expenses made or incurred outside Canada as described in s. 217.1(2). ...