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Results 961 - 970 of 28992 for consideration

Medsleep Inc. v. The King, 2025 TCC 70 -- summary under Section 2

In rejecting the Crown's position that such 20% share was taxable consideration for administrative, billing and marketing services supplied to the sleep physicians by MedSleep, Bodie J found that: The fee-sharing agreements were valid for tax purposes notwithstanding that, under provincial health care law, payments for physicians’ services could be made by the provincial health insurance plans to physicians only; and The fee-sharing agreements did not contemplate that MedSleep would provide the alleged admin and marketing services to the sleep physicians and they instead indicated that MedSleep was entitled to a portion of the professional fees generated from medical services provided to the patients. ... V-II-2 (the consideration for which was both its directly charged fees and its 20% share of the sleep physicians' fees), Bodie, J. found that MedSleep, in tandem with the sleep physicians, supplied institutional health care services referred to in both paras. ...

11 April 2005 External T.I. 2005-0112321E5 F - Price adjustment clause -- summary under Subsection 51(2)

11 April 2005 External T.I. 2005-0112321E5 F- Price adjustment clause-- summary under Subsection 51(2) Summary Under Tax Topics- Income Tax Act- Section 51- Subsection 51(2) CRA may accept a price adjustment clause adjusting of share consideration on s. 51 exchange if genuine attempt to establish FMV and issue of intervening share cancellation is addressed An estate freeze entailed the exchange by Mr. A of his common shares of Opco by way of purchase for cancellation for Class A preferred shares with a redemption value of $1 million, followed by a common share subscription by his two adult children for nominal consideration. ... A as consideration, Mr. A and Opco would agree to exchange the those Class A preferred shares for an equal number of Class B preferred shares. ...

Rosenblat v. The Queen, 75 DTC 5274, [1975] CTC 472 (FCTD) -- summary under Shares

The Queen, 75 DTC 5274, [1975] CTC 472 (FCTD)-- summary under Shares Summary Under Tax Topics- General Concepts- Fair Market Value- Shares The taxpayer was granted the right to acquire 300,000 shares of a corporation in consideration of past services in June of 1967 and the shares were issued to him in December. ...

R. v. Pavely, 76 DTC 6415, [1976] CTC (Sask. C.A.) -- summary under Paragraph 239(1)(d)

"The word 'wilfully' as used in the subsection under consideration, carries a distinct connotation of deliberate purpose and ulterior motive. ...

Riviera Hotel Co. Ltd. v. The Queen, 82 DTC 6045, [1982] CTC 30 (FCTD) -- summary under Evidence

The Queen, 82 DTC 6045, [1982] CTC 30 (FCTD)-- summary under Evidence Summary Under Tax Topics- General Concepts- Evidence Statements in tax returns that "were not made inadvertently but only made following due consideration and professional advice... constitute statements against interest. ...

Ostime v. Duple Motor Bodies Ltd., [1961] 2 All E.R. 167 (HL) -- summary under Resolving Ambiguity

., [1961] 2 All E.R. 167 (HL)-- summary under Resolving Ambiguity Summary Under Tax Topics- Statutory Interpretation- Resolving Ambiguity [T]he prevailing consideration must be that the taxpayer should not be put to any risk of being charged with a higher amount of profit than can be determined with reasonable certainty. ...

MNR v. Shawinigan Water and Power Co., 53 DTC 1036, [1953] CTC 37 (Ex Ct) -- summary under Legislative History

., 53 DTC 1036, [1953] CTC 37 (Ex Ct)-- summary under Legislative History Summary Under Tax Topics- Statutory Interpretation- Legislative History Any doubt as to the meaning of s. 6(1)(o) was "entirely removed by a consideration as to how the law stood and the state of things existing at the time para. ...

SLM Direct Marketing Ltd. v. The Queen, 2007 TCC 415 (Informal Procedure) -- summary under Agency

Accordingly, the postage paid by it was 0-rated consideration. ...

Tory Estate v. M.N.R., 73 DTC 5354, [1973] CTC 434 (FCA), briefly aff'd 76 DTC 6312, [1976] CTC 415 (SCC) -- summary under Subsection 88(1)

., 73 DTC 5354, [1973] CTC 434 (FCA), briefly aff'd 76 DTC 6312, [1976] CTC 415 (SCC)-- summary under Subsection 88(1) Summary Under Tax Topics- Income Tax Act- Section 88- Subsection 88(1) The word "distributed" was held not to include a sale of accounts receivable for valuable consideration. ...

Husel Estate v. The Queen, 94 DTC 1765, [1995] 1 CTC 2298 (TCC) -- summary under Subsection 70(6)

The Queen, 94 DTC 1765, [1995] 1 CTC 2298 (TCC)-- summary under Subsection 70(6) Summary Under Tax Topics- Income Tax Act- Section 70- Subsection 70(6) A transfer of shares to the wife of the deceased in consideration for cash and set-off of debts owing to her by the estate occurred pursuant to a purchase transaction rather than as a consequence of the death of the deceased. ...

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