Search - consideration

Consequently, subparagraph 66.1(6)(a)(iv) operates for partners to receive their share of the CEE incurred by partnerships in consideration for flow-through shares. ... In other words, expenses which are CEE by virtue of subparagraphs (i) to (iii.1) would be disqualified from treatment as CEE if the expenses were incurred in consideration for shares of a corporation. ... Consequently, subparagraph 66.1(6)(a)(iv) operates for partners to receive their share of the CEE incurred by partnerships in consideration for flow-through shares because such CEE referred to in subparagraph (v) is identical to that in (iv). ...

There is no requirement that the consideration given to a resource expenditures. The consideration for which the Shares are issued will be valued at it fair market value at that time. ... If the value of the property is $1,000, the consideration given for the flow-through shore agreement with the issuing corporation would renounce resource expenditures to the taxpayer in an amount equal to $1,000. ...

The consideration to be received by XXX According to the schedule provided in your request, the consideration to be received is significantly less than the current fair market value of the property being transferred. ... This paragraph operates to deny the capital gains deduction to an individual where a capital gain has been realized from the disposition of property as part of a series of transactions in which any property is acquired by a corporation for consideration that does not approximate its fair market vallue at the time of acquisition. It should be noted that the draft legislation to implement the income tax reform measures proposes to amend this provision to apply in situations where the consideration received is significantly less than the fair market value of the property at the time of acquisition. ...

Corporation B agrees to issue as consideration, an agreed number of its common shares and to enter into the appropriate agreements, file the prescribed forms, etc. so that the shares will be flow-through shares for purposes of paragraph 66(15)(d.1) of the Act. 5. ... There is no requirement that the consideration given to a resource corporation for the Shares be property used to incur resource expenditures. The consideration for which the Shares are issued will be valued at its fair market value at that time. ...

Consequently, subparagraph 66.1(6)(a)(iv) operates for partners to receive their share of the CEE incurred by partnerships in consideration for flow-through shares. ... In other words, expenses which are CEE by virtue of subparagraphs (i) to (iii.1) would be disqualified from treatment as CEE if the expenses were incurred in consideration for shares of a corporation. ... Consequently, subparagraph 66.1(6)(a)(iv) operates for partners to receive their share of the CEE incurred by partnerships in consideration for flow-through shares because such CEE referred to in subparagraph (v) is identical to that in (iv). ...

Position: Either of subsections 6(1) or 15(1) of the Act may apply to include in the income of the individual, as the case may be, the amount by which the fair market value of the policy exceeds any actual consideration paid by the individual for the policy. ... Upon its renewal, the policy is transferred to the employee for no consideration under subsection 148(7) of the Act. ... Can the CRA confirm that, since the key employee has effectively been paying the premium under the policy in the form of a taxable benefit, that no employee benefit will arise on the transfer of the policy to the key employee for no consideration? ...

The consideration to be received by XXXX According to the schedule provided in your request, the consideration to be received is significantly less than the current fair market value of the property being transferred. ... This paragraph operates to deny the capital gains deduction to an individual where a capital gain has been realized from the disposition of property as part of a series of transactions in which any property is acquired by a corporation for consideration that does not approximate its fair market value at the time of acquisition. It should be noted that the draft legislation to implement the income tax reform measures proposes to amend this provision to apply in situations where the consideration received is significantly less than the fair market value of the property at the time of acquisition. ...

A personal trust as defined in subsection 248(1) of the Act includes an inter vivos trust in which no beneficial interest was acquired for consideration payable to the trust or to any person who has made a contribution to the trust. It is your view that a self-directed RRSP trust meets this definition because it is an inter vivos trust in which no beneficial interest was acquired for consideration. You have indicated that since all of the beneficial interests in such a trust are acquired by one person, subparagraph (b)(iii) of the definition deems the beneficial interest to be acquired for no consideration. ...

In such cases, there would be dispositions of the property for proceeds equal to the fair market value of the consideration received. It is necessary to distinguish property "settled" on the trust for nil proceeds from property sold to a trust in return for valuable consideration." ... In your opinion, paragraph 54(c)(v) of the Act can be applicable to a transfer to a trust whether or not there is consideration. ...

Shares transferred to spouse for no consideration. No 74.5(1) election. ... Shares have been disposed of and no consideration received. 2. Depends on fair market value of shares at time of disposition. ... When the property is disposed of for consideration which is less than the fair market value of the property, the excess of the amount of the borrowed money over the fair market value of the property at the time of disposition will be deemed to be used for the purpose of earning income and, consequently, the interest expense on that excess amount will continue to be deductible pursuant to paragraph 20(1)(c) of the Act. ...