Earlier this year, the CRA said that nominal consideration for a non-compete would be proceeds of disposition so that 56.4(7) would not apply to the covenant. Apparently, the CRA reversed this position at the CTF Roundtable yesterday: $1 (but no more?) will not be considered proceeds for a non-compete so that the rules in 56.4(7) will be available.
Well, that’s one less thing to worry about. Many problems remain, however, when trying to apply the 56.4 rules in the real world.