Words and Phrases - "consideration"

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8 October 2021 APFF Roundtable, Q.14

“consideration … received” in s. 118.1(13)(c) includes a s. 84(3) deemed dividend
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Words and Phrases
consideration

Odette (Estate) v. The Queen, 2021 TCC 65

a promissory note subsequently repaid in cash could not be equated to cash consideration for s. 118.1(13)(c) purposes
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Words and Phrases
consideration receive payment

Centre de traitement de la biomasse de la Montérégie inc. v. Agence du revenu du Québec, 2021 QCCA 1068

consideration for a transfer of waste included the assumption of environmental responsibility
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Words and Phrases
consideration sale
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 125.1 - Subsection 125.1(3) - Canadian Manufacturing and Processing Profits a taxpayer made sales of partially processed waste when it paid other processors to complete its processing 354

National Car Parks Ltd v Revenue and Customs, [2019] EWCA Civ 854

car park machines that did not refund coin payments thereby received extra consideration for VAT purposes
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Words and Phrases
consideration

MEO — Serviços de Comunicações e Multimédia SA v. Autoridade Tributária e Aduaneira, (2018), ECLI:EU:C:2018:942 (ECJ (5th Chamber))

payments pursuant to contract for remaining minimum service term were consideration
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Words and Phrases
consideration
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 182 - Subsection 182(1) fee for early termination of services contact was consideration for the service 149

Placer Dome Canada Ltd. v. Ontario (Minister of Finance), 2006 DTC 6532, 2006 SCC 20, [2006] 1 S.C.R. 715

cash-settled derivatives had the effect of fixing mine production]
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Words and Phrases
consideration
Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Interpretation Bulletins, etc. shifting CRA position could not be relied upon except to evidence ambiguity 79
Tax Topics - Statutory Interpretation - Redundancy/reading in words presumption against tautology 120
Tax Topics - Statutory Interpretation - Resolving Ambiguity residual presumption in favour of the taxpayer 133
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Futures/Forwards/Hedges “hedging “ includes cash settled derivatives including options 461
Tax Topics - Statutory Interpretation - Regulations/Statutory Delegation addition of regulation did not significantly expand scope of tax 264

Dale v. The Queen, 94 DTC 1100, [1994] 1 CTC 2303 (TCC), aff'd supra.

shares must be issued within a reasonable time
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Words and Phrases
consideration

Fiducie Famille Gauthier v. The Queen, 2011 DTC 1343 [at 1917], 2011 TCC 318, aff'd 2012 FCA 76

agreement to bear costs was additional consideration
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Words and Phrases
consideration
Locations of other summaries Wordcount
Tax Topics - General Concepts - Substance 233

Groupmark Canada Ltd. v. The Queen, 93 DTC 5179, [1993] 1 CTC 234 (FCTD)

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Words and Phrases
consideration

Canada v. Toronto Refiners and Smelters Ltd., 2003 DTC 5002, 2002 FCA 476

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Words and Phrases
consideration

Dowbrands Canada Inc. v. The Queen, [1997] GSTC 85 (TCC)

rebates reduced consideration but no obligation to rebate GST
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Words and Phrases
consideration

Global Cash Access (Canada) Inc. v. Canada, 2013 FCA 269

"consideration" under law of contract
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Words and Phrases
consideration
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Consideration "consideration" under law of contract 123
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (g) commercial efficacy of arrangement involving kiosk and support services turned on the advance of money 428
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply three elements integrally connected 240
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.4) predominant element not described in (r.4) or (r.5) 183

Commission Scolaire des Chênes v. Canada, [2002] GSTC 11, 2001 FCA 264

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Words and Phrases
consideration
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Consideration provincial subsidy was paid only if busing services provided 192

Boardwalk Equities Inc. v. Canada, 2013 FCA 140, aff'g Calgary Board of Education v. The Queen, 2012 TCC 7

consideration not reduced by credit for subsequent provincial subsidy
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Words and Phrases
consideration

Canada v. Costco Wholesale Canada Ltd., 2012 FCA 160

Costco agreement to use Amex cards exclusively was "arranging for" support of Amex's supply of credit
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Words and Phrases
consideration
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 153 - Subsection 153(1) payments by credit card company to store were not merely discounts to its fees 184