Search - consideration

Sexton J.A. stated (at p. 7119) that "Technical Notes are not binding on the courts, but they are entitled to consideration." ...

The bulk of the total consideration was allocated to the building. ...

.), rev'd [1980] BTC 239 (HL)-- summary under Paragraph 69(1)(b) Summary Under Tax Topics- Income Tax Act- Section 69- Subsection 69(1)- Paragraph 69(1)(b) "[T]he ordinary primary meaning of 'gift' is a voluntary transfer of property made without consideration." ...

MNR, 58 DTC 676 (TAB)-- summary under Subparagraph 20(1)(p)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(p)- Subparagraph 20(1)(p)(i) The consideration received by the taxpayer on the sale of a theatre, which gave rise to recapture of depreciation to it, included the assignment to it of a debt owing by the purchaser. ...

The Queen, 82 DTC 6311, [1981] CTC 421 (FCTD)-- summary under Subsection 174(3) Summary Under Tax Topics- Income Tax Act- Section 174- Subsection 174(3) Notwithstanding the desire of counsel both for the taxpayer and the Crown to limit discussion to the narrow question before the Court, the Court is entitled "to widen the discussion sufficiently to embrace the true nature of the transaction [under consideration] and the circumstances surrounding it". ...

The Queen, 2012 DTC 1106 [at at 3044], 2012 TCC 86-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt past services Margeson J. accepted (at para. 99) that employees to whom the taxpayer issued shares in payment of bonuses to them gave consideration equal to the full value of those share "on the basis of past unremunerated services rendered to the Appellant. ...

The Queen, docket 2001-862-GST-I (TCC) (Informal Procedure)-- summary under Financial Service Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Financial Service A fee received by the taxpayer for agreeing not to bid for the assets of an insolvent corporation did not represent consideration for a financial service. ...

Customs and Excise Commissioners, [2000] BTC 5153 (QBD)-- summary under Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Supply The surrender of hand guns by the taxpayer to the government and the receipt of compensation therefor constituted a supply for consideration given that there was a transfer of title to the government. ...

James' Chambers in consideration for a percentage of the gross fees of each barrister, did not hold an "office". ...

Canada, 2003 DTC 5225, 2003 FCA 128-- summary under Exempt Receipts/Business Summary Under Tax Topics- Income Tax Act- Section 9- Exempt Receipts/Business non-taxable non-compete Consideration received by the taxpayer for giving a non-compete covenant on the sale of shares of companies owned by him directly or through holding companies was found to be a non-taxable capital receipt. ...