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In consideration, the Funds agreed to pay Funding Corp a portion of the management fees that otherwise would have been payable by them to the Fund manager (the “Manager”) and which the Manager had agreed to relinquish (the “Earned Fees”), which were expressed to be fees paid by the Funds for the services rendered to them in the U.S. by Funding Corp in arranging for the daily funding of the brokerage commissions. ... CRA assessed on the basis that the Earned Fees were consideration for an imported taxable supply. ...

…[T]he record demonstrates no consideration or weighing at all of the Applicant’s submissions as to the effect upon it, and its ability to pay its HST liability, that would result from its request being refused. The failure to consider these factors may be attributable to the [User Guide – Re-appropriation of T2 Statute-barred Credits] Guidelines’ emphasis on consideration of whether there were extraordinary circumstances which prevented the filing of returns within three years from the applicable tax year end. ...

Ltd. to Old Flora for consideration consisting of a promissory note for $1,951,457 and a Class A Preferred share worth $1. ... Business Corporations Act (the “BCA”) to correct this “corporate” mistake by changing the consideration to a promissory note for $1 and Class A Preferred Shares for 1,951,457. ...

When GAM proposed that SLT be merged with another fund managed by GAM in which non-residents were investors, it was agreed that, in light of the merged fund being subject to a higher level of fees than those to which SLT had been subject, that a Bermuda company owned indirectly by two Steinberg and Ludmer non-resident trusts would receive annual “fees” from the time of the 1994 merger that effectively represented a rebate of the higher fees imposed on the Canadian investors (although they were described to be consideration for services that, in fact, were never provided). ... Moreover, there is also the issue of the contracts which state that Sandringham was receiving the payments in consideration for “investment consultancy services”. ...

. … Although the judgment of the Superior Court is not binding on the respondent and is not res judicata, the conduct of the parties, both before and after the concluding of the transaction, clearly demonstrates their true intention to purchase and sell the shares of Quatre Saisons for nominal consideration and not for consideration based on the future sales of lots. ...

After finding that each purchased interest qualified as a qualified investment, D'Arcy J then found that such mortgage interests had a fair market value that equaled rather than being less than the cash consideration paid by the RRSPs therefor, so that s. 146(9)(b) was not engaged, stating (at paras 68- 70, and 72): They paid a price negotiated with an arm’s length vendor, namely Mr. ... …[P]aragraph 146(9)(b) does not apply in a situation where a taxpayer directs his/her RRSP to make an investment with an arm’s length party for what the taxpayer believes is a fair market value consideration and the investment turns out to be a poor investment. … Justice Sharlow … [in Arnaud] concluded that paragraph 146(9)(b) did not apply to the case before her since there was no collateral arrangement. … [T]he appellants here did not enter into any collateral agreement that would have allowed them to recover their loss in whole or in part. ...

The Agreement provided that the fees of AC were payable by CIBC “in consideration of AC referring or arranging for Aeroplan members and other members of the public to make Card Applications and in consideration of AC performing its other obligations herein which are incidental to the foregoing.” ...

Canada, 2019 FCA 217-- summary under Paragraph 262(2)(b) Summary Under Tax Topics- Excise Tax Act- Section 261- Subsection 261(2)- Paragraph 262(2)(b) denial includes where the CRA assessment of the tax was of another person A non-resident bank ("Citibank") agreed to fund the payment of the upfront brokerage commissions that were payable on the issuance of units in the Invesco/Trimark funds (the “Funds”) in consideration for receiving an assignment of a portion of the amounts that otherwise would have been earned by the Invesco manager as management fees. More precisely, the manager agreed to reduce its management fees (i.e., reduce its percentage charge of NAV), and the Funds agreed to pay the same percentage amounts to a special purpose non-resident Citibank-formed vehicle (“Funding Corp”) essentially in consideration for Funding Corp paying the brokerage commissions. ...

Expense- Contract Purchases or Prepayments lump sum payments made to lock-up doctors as customers for a 5-year period were currently deductible The taxpayer was an Australian public company that provided (including, relevantly, through a subsidiary trust (“Idameneo”) whose results were consolidated for tax purposes with its own medical centre facilities and services to doctors in consideration for 50% of the fees generated by them. In order to induce a doctor to join one of the medical centres operated by it, it would typically pay a lump sum in the range of $300,000 to $500,000 to the doctor in consideration for the doctor’s promise to conduct his or her practice from the medical centre for a specified period (generally around five years) and not to provide medical services to anyone within a radius of, say, 7km of the medical centre or the doctor’s own former practice at that practice’s previous location within that period. ...

He then added (at para. 51): I believe that the Crown’s stubborn clinghold to the Tariff amount, and its incorrect view that this Court needs to identify a principled reason to depart from the Tariff, gives rise to Rule 147(3)(g), (h) and (i) considerations. These, in addition to (a), (b) and (e) considerations, all favour a higher award of costs on this costs motion. … ...