Search - consideration

However, …taking into consideration the flexible tracing approach mandated… in Ludco …as well as the comments in paragraph 1.38 of the Folio …Amalco would be entitled to allocate the entire amount of the Assumed Debt to its assets other than the FA shares. ...

Generally, a plan…[is] a superannuation or pension plan where contributions have been made to the plan by or on behalf of an employer or former employer of an employee in consideration for services rendered by the employee and the contributions are to be used to provide an annuity or other periodic payment on or after the employee's retirement. ...

The maintenance of legal stated capital in a foreign currency does not change any of these answers as PUC is fundamentally a C$ tax concept, absent functional currency considerations. ...

B, for no consideration, ½ of her preferred shares, thereby realizing under s. 73(1) proceeds of disposition deemed to be equal to the ACB of those shares of $500,000. ...

The Court of Quebec ruled in favor of the contributor in a decision animated more by considerations of fairness than by an analysis of the legislative provisions. ...

(“Holdco 2 Inc.”) in exchange for the issuance of preferred shares Holdco Inc. will transfer a rental property and its shares of Opco 1 Inc. to Holdco 2 Inc. on a s. 85(1) rollover basis in consideration for the issuance of preferred shares the resulting cross preferred shareholdings will be redeemed and the resulting notes settled. ...

. … In addition … a likelihood of a particular production generating revenues other than those provided for in the original broadcast contract, for example, from the sale of DVDs, the awarding of contracts for broadcasting on the Internet, on specialty channels or in territories not covered by the original broadcast contract, can also be taken into consideration in determining whether the costs related to a production should be considered as capital expenditures in respect of depreciable property. … [W]here the broadcast contract covers a period of several years, under which the broadcaster has the right to broadcast the production several times during that period, this would be an argument to support that the costs associated with the production provide a lasting benefit to the producer. ...

Since … paragraph 69(1)(b) is applicable in this case, the original beneficiaries will be deemed to have received, as a result of the partial disposition of their interests, consideration equal to the fair market value of those interests. … (b) In the event that the courts approve the addition of a beneficiary that is a corporation in which a majority of the voting and participating shares are held by persons other than the original beneficiaries of the trust, it would first have to be determined whether the change is significant enough to give rise to a new trust and, consequently, to a disposition of all the property of the old trust to the new trust. ...

CRA responded: [W]e believe that the partner, in consideration for the $100,000 payment, acquired a greater interest in the partnership by acquiring part of a property. ...

., someone who would not receive any benefits from the municipality as employment or business income) would reference the situation where any consideration paid “does not adequately reflect the amount of work performed nor the quality of the services provided (whereas “where the amount of remuneration paid … is sufficient to influence their involvement or participation, it is very likely that the remuneration is taxable as employment income or income from a business”), CRA went on to say that, in the context of s. 81(4): The volunteer firefighters we are referring to are not necessarily volunteers in the sense established above. ...