Search - consideration

The determination in a particular situation would be based on consideration of all the relevant facts and supporting documentation. This may include consideration of an opinion of a qualified medical practitioner describing the nature and purpose of the procedure in sufficient detail in order to be able to make a determination. ...

Generally, a plan will be considered a superannuation or pension fund or 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 used to provide an annuity or other periodic payments on or after the employee's retirement in consideration for his or her employment services. ...

The determination as to whether the gain on the disposition of such a property will treated as ordinary income under subsection 9(1) of the Act or as a capital gain is a determination of fact to be based on a review of the documents and circumstances of the case under consideration. ... In other cases where capital property has been disposed, the consideration would be proceeds of disposition, which may result in a taxable capital gain under section 38 of the Act and, if the property disposed of was depreciable property in the transferor's hands, recaptured capital cost allowance. ...

As part of its review of a particular case, the CRA will give consideration to the existence of a court order or agreement; however, the only legal authority for determining benefit eligibility is the ITA. ... In applying the provisions of the ITA, the CRA will give consideration to all the documentation and factors to ascertain whether the couple is living separate and apart. ...

., land and building) before Individual A disposed of the Xco shares, the determination of whether the SBC test in (1) has been met at the time of the disposition of the shares would depend on the type and use of the consideration, if any, that Xco received from Individual A for the land and building. Whether or not such consideration is used by Xco in an active business is a question of fact. ...

He receives a promissory note ("PN") as consideration. The individual then plans to buy back the house from his parents, to use as a rental property, by taking a mortgage on the property. ... A as consideration for this buy-back and Ms. A uses the proceeds to pay off the Promissory Note she issued on the purchase of the property the day before; The proceeds from the Promissory Note are used by the Appellant to pay off the first bank loan; The only remaining loan is the second loan taken to acquire a rental property; Everything is done at fair market value without tax consequence, and actual transfers of land need never be registered. ...

We recognize that the Act does not specifically define the cost of a life insurance policy and we have brought this to the attention of the Department of Finance for consideration." ... As stated by the CRA at the CLHIA Roundtable in May 2009, we recognize that the Act does not specifically define the cost of an interest in a life insurance policy and we have brought this to the attention of the Department of Finance for their consideration. ...

Headquarters will generally in turn refer the matter to the GAAR Committee for consideration. ... Thus taxpayers should be assured that when the application of the GAAR is considered, all their arguments will have received careful consideration. ...

Headquarters will generally in turn refer the matter to the GAAR Committee for consideration. ... Thus taxpayers should be assured that when the application of the GAAR is considered, all their arguments will have received careful consideration. ...

Generally, a plan will be considered to be 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. ... A self-funded XXXXXXXXXX PPS would not be considered a superannuation or pension plan where contributions are not made to the XXXXXXXXXX PPS by or on behalf of an employer of the beneficiary of the XXXXXXXXXX PPS in consideration for services rendered by the beneficiary. ...