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4 December 2012 Internal T.I. 2011-0431871I7 - Part XIII and Procurement Fees -- summary under Paragraph 212(1)(d)

Consideration to USCo includes a fixed monthly fee, a percentage of gross receipts, and a "Procurement License Fee" ("PLF"). ... Rejecting the taxpayer's contention that the PLF is consideration for a set of "procurement rights" distinct from the other franchise rights, CRA stated: [I]t can be argued the PLF is a substitute for the obligation to purchase products and equipment from USCo that would otherwise have been given as consideration for the grant of the Franchise Rights. ... Regardless of whether or not the PLF is separate consideration, it is not a rent, royalty or similar payment. ...

2018 Ruling 2017-0714411R3 - Butterfly Reorganization -- summary under Distribution

Child 2 will transfer all his Class B and common shares of DC to TC under s. 85(1) in consideration for TC common shares. Mother will transfer all her Class B shares of DC to TC under s. 85(1) in consideration for TC non-cumulative non-participating redeemable retractable non-voting Class A special shares. ... As part of such transfer, DC will transfer a percentage interest in the Mother insurance policy, and all of the Child 2 policy, to TC for proceeds determined in accordance with s. 148(7) as the greater of the value of the interest; the FMV of the consideration given therefor; and the adjusted cost basis of the interest and the consideration therefor, in each case being a non-interest bearing demand promissory note in the principal amount equal to the FMV of the policy. ...

Minister of National Revenue v. Shofar Investment Corporation, 79 DTC 5347, [1979] CTC 433, [1980] 1 SCR 350 -- summary under Subsection 78(1)

The predecessor of s. 78(1) accordingly did not apply to a non-arm's length sale of land inventory for a consideration to be paid over a 7-year period. ...

Lloyd v. The Queen, 2002 DTC 1493 (TCC) -- summary under Subsection 84.1(1)

Among other things, none of the stipulated consideration was ever paid by the holding company and the directors of READ did not approve the transfer as required by the articles. ...

Fortino v. R., 97 DTC 55, [1997] 2 CTC 2184 (TCC), briefly aff'd on procedural grounds 2000 DTC 6060 (FCA) -- summary under Section 3

., 97 DTC 55, [1997] 2 CTC 2184 (TCC), briefly aff'd on procedural grounds 2000 DTC 6060 (FCA)-- summary under Section 3 Summary Under Tax Topics- Income Tax Act- Section 3 Lump sums received by individual vendors of shares in consideration for their entering into non-competition agreements with the purchaser were characterized as being for their surrender of a potential source of profit and, therefore, represented capital receipts that were not taxable under s. 3. ...

Fortino v. R., 97 DTC 55, [1997] 2 CTC 2184 (TCC), briefly aff'd on procedural grounds 2000 DTC 6060 (FCA) -- summary under Exempt Receipts/Business

., 97 DTC 55, [1997] 2 CTC 2184 (TCC), briefly aff'd on procedural grounds 2000 DTC 6060 (FCA)-- summary under Exempt Receipts/Business Summary Under Tax Topics- Income Tax Act- Section 9- Exempt Receipts/Business Lump sums received by individual vendors of shares in consideration for their entering into non-competition agreements with the purchaser were characterized as being for their surrender of a potential source of profit and, therefore, represented capital receipts that were not taxable under s. 3. ...

Fortino v. R., 97 DTC 55, [1997] 2 CTC 2184 (TCC), briefly aff'd on procedural grounds 2000 DTC 6060 (FCA) -- summary under Expense Reimbursement

., 97 DTC 55, [1997] 2 CTC 2184 (TCC), briefly aff'd on procedural grounds 2000 DTC 6060 (FCA)-- summary under Expense Reimbursement Summary Under Tax Topics- Income Tax Act- Section 9- Expense Reimbursement Lump sums received by individual vendors of shares in consideration for their entering into non-competition agreements with the purchaser were characterized as being for their surrender of a potential source of profit and, therefore, represented capital receipts that were not taxable under s. 3. ...

Brown v. The Queen, 2001 DTC 1094 (TCC), aff'd supra 2003 DTC 5298 (FCA) -- summary under A

The Queen, 2001 DTC 1094 (TCC), aff'd supra 2003 DTC 5298 (FCA)-- summary under A Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Undepreciated Capital Cost- A Rip T.C.J. accepted the position of the Minister that a note issued by a partnership as part of the consideration for the purchase by it of software "engines" was a contingent note because interest and principal on it were payable only out of stipulated percentages of gross profits generated by the software. ...

Chabaud c. La Reine, 2012 DTC 1076 [at at 2856], 2011 TCC 438 (Informal Procedure) -- summary under Paragraph 56(1)(o)

La Reine, 2012 DTC 1076 [at at 2856], 2011 TCC 438 (Informal Procedure)-- summary under Paragraph 56(1)(o) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(o) Archambault J. found that "bursary" amounts that the taxpayer received from the University of Laval in connection with his postdoctoral fellowship at that university were not research "grants" (which had been judicially defined as financial assistance) because they instead represented consideration for (employment) services rendered by the taxpayer. ...

Insight Venture Associates III, LLC v. SLM Soft Inc. (2003), 67 O.R. (3d) 115 (S.C.J.) -- summary under Paid-Up Capital

.)-- summary under Paid-Up Capital Summary Under Tax Topics- Income Tax Act- Section 89- Subsection 89(1)- Paid-Up Capital stated capital increase equal to principal of converted debt With respect to s. 23 of the Ontario Business Corporations Act … the effect of the conversion [of] a debt security into shares releases the corporation from liability for the principal amount of the debt security and that constitutes the consideration for the issuance of the shares. ...

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