Search - consideration

13 November 1992 T.I. 923187 (September 1993 Access Letter, p. 423, ¶C144-239)-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition Where a subscriber to an RESP names another person's child as a beneficiary in consideration of the receipt of a lump sum, the subscriber will thereby be disposing of a property giving rise to a capital gain. ...

31 October 2011 Ruling Case No. 136392-- summary under Sale Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Sale The granting of easements in consideration for a single lump sum payment was ruled to be a supply of real property by way of sale even though under the governing law the easements could not be granted for an unlimited term. ...

31 October 2011 Ruling Case No. 136392-- summary under Subsection 221(2) Summary Under Tax Topics- Excise Tax Act- Section 221- Subsection 221(2) The granting of easements in consideration for a single lump sum payment was ruled to be a supply of real property by way of sale even though under the governing law the easements could not be granted for an unlimited term. ...

17 September 1997 External T.I. 9721415- INTERACTION OF SUBSECTION 55(2) & DIVIDEND REFUNDS-- summary under Subsection 55(2) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2) The fact that a dividend refund has been received by the payor of a dividend is not normally relevant to consideration of the following expression: "that is not refunded as a consequence of the payment of a dividend to a corporation where the payment is part of the series of transactions or events". ...

30 November 1997 Ruling 9732433 F- UTILISATION DE PERTES LOSS UTILIZATION-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) Consideration of the reasonableness of an interest rate (8.7%) before giving favourable rulings on an arrangement respecting the deductibility of interest on money borrowed in order to redeem shares that had permitted the utilization of losses within a corporate group. ...

3 June 1994 Internal T.I. 9405427- DEDUCTIBILITY OF INTEREST UNDER 20(1)(C)-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) Consideration of interest deductibility in a situation where a loan is used to purchase preferred shares which are exchanged for common shares of a related company three months after their acquisition. ...

24 August 1994 Internal T.I. 9420517- INTEREST DEDUCTIBILITY-- summary under Subsection 20(3) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(3) Where the assets of a proprietorship are transferred to a corporation for consideration including a note payable, interest on money borrowed by the corporation from a financial institution to repay such note will be deductible. ...

6 September 1994 External T.I. 9420525- DIRECTOR-STOCK OPTIONS-- summary under Subsection 7(5) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(5) Options are received by a director in respect of an employment where the options were granted to the director in consideration for the services to be performed as director. ...

24 September 1996 External T.I. 9627705- DONATIONS/TUITION FEES-- summary under Total Charitable Gifts Summary Under Tax Topics- Income Tax Act- Section 118.1- Subsection 118.1(1)- Total Charitable Gifts Unlike teaching or other training, religious training is not viewed as consideration for purposes of the definition of a gift. ...

24 May 1995 External T.I. 9420675- WYOMING LLCS-- summary under Subsection 85(1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1) An interest in a Wyoming LLC receivable by a taxpayer as consideration for the disposition of shares of a foreign affiliate to the LLC would constitute "shares of the capital stock of the acquiring affiliate" provided that the LLC otherwise qualified as a foreign affiliate of the taxpayer immediately after the disposition. ...