Search - consideration

The Queen, 84 DTC 6494, [1984] CTC 466 (FCTD), rev'd 85 DTC 5433, [1985] 2CTC 214 (FCA)-- summary under Paragraph 60(f) Summary Under Tax Topics- Income Tax Act- Section 60- Paragraph 60(f) A tuition fee was defined as "the monetary consideration (money or, money's worth of goods or services) payable to a pedagogue or school authority for enrolling a pupil or student in an instructional, training or educational lecture or course of lectures. ...

Canada, 2008 DTC 6513, 2007 FCA 16-- summary under Subsection 6(3) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(3) non-solicitation covenant taxable A lump sum received by the taxpayer, who was an investment advisor employed by a Canadian securities firm, on the termination of his employment was found to constitute consideration for his covenant (contained in the termination agreement) not to solicit clients given that "the non-solicitation covenant is at the heart of the termination agreement, which makes no mention of any sale of assets" (para. 16). ...

Canada, 2002 DTC 7061, 2002 FCA 212-- summary under Subsection 160(1) Summary Under Tax Topics- Income Tax Act- Section 160- Subsection 160(1) The taxpayers had been unsuccessful in establishing an alleged connection between service rendered by them and dividends on shares held by them, so that it was not necessary to determine, for the purposes of section 160, whether the work presumably performed could constitute valuable consideration for the issuance of dividends. ...

Bonner J. found that the contributions of the taxpayers to the shared costs of running the household were unrelated to the transfer to them of the condominium and, therefore, did not represent consideration for the transfer. ...

Profit- Copyright £150 that a practising lawyer received from an English publisher for permission to publish a 6th edition of his "History of the English Courts" was a capital receipt, it being agreed that for purposes of the appeal the £150 should not be treated as representing consideration for what little work he did in revising the book. ...

The rejection by the Department of a request for waiver of interest following a consideration of the matter by a fairness committee, and a review of the committee's decision by the Director of the District Office in conjunction with another, did not entail a breach of the Minister's duty to act fairly or to consider relevant evidence. ...

The Queen, 86 DTC 6322, [1986] 2 CTC 71 (FCTD)-- summary under Subparagraph 40(1)(a)(iii) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(1)- Paragraph 40(1)(a)- Subparagraph 40(1)(a)(iii) The reserve was not available in respect of a demand promissory note received by the vendors as partial consideration for the sale of shares of a family farm corporation, notwithstanding that the shares were held subject to an escrow agreement until the promissory note was paid off. ...

The Queen, 2005 DTC 959, 2005 TCC 335-- summary under Price Adjustment Clause Summary Under Tax Topics- General Concepts- Price Adjustment Clause The existence of an "anti-flip agreement" allegedly given by the taxpayer in connection with its purchase of shares (under which it would pay to the vendor any consideration received by it, on a subsequent sale by it of the shares, over and above the purchase price) was found not to be supported by the evidence. ...

The residuum thereby allocated to the bare land was small: $60,000 out of a total consideration of $230,000. ...

MNR, 2 DTC 918 (Ex Ct) in finding that although an agreement between the taxpayer and an American company indicated that payments were made solely in consideration for the right to use a line of clothing and the associated name, the taxpayer's evidence that the terms of the agreement also required the provision to the taxpayer of services, was admissible. ...