Search - consideration

"The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including motion pictures and works on film, videotape or other means of reproduction for use in connection with television), any patent, trade mark, design or model, plan, secret formula or process, or for the use of, or the right to use, tangible personal property or for information concerning industrial, commercial or scientific experience, and, notwithstanding the provisions of Article XIII (Gains), includes gains from the alienation of any intangible property or rights described in this paragraph to the extent that such gains are contingent on the productivity, use or subsequent disposition of such property or rights." Netherlands "The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including motion picture films and works on film, videotape or other means of reproduction for use in connection with television, any patent, trade mark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment or for information concerning industrial, commercial or scientific experience. ...

The calculation of the amount or value of the benefit is usually based on the fair market rent for the property minus any consideration paid to the corporation by the shareholder for the use of the property. ... Any consideration paid to the corporation by the shareholder for the use of the property is then subtracted from the imputed rent. ...

That is, the Department is concerned that the value of the preferred shares (ie. the "freeze shares") plus other consideration given must equal the fair market value of the asset being transferred or exchanged, as the case may be. ...

In the Department's view, the guidelines set out in this Interpretation Bulletin are a reasonable distillation of the relevant considerations developed by the Courts. ... Since you have already sent your letter to the Minister of Finance, I am certain that your views will receive every consideration. ...

In our opinion, this will only occur 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 or in some cases, where amounts have been contributed by a government. ... An annuity or other periodical payment made, esp. by a government, a company, or an employer of labour, in consideration of past services. ...

If the date the person went missing is used, some assessments will need to be cancelled, some options may not be available and consideration must be given to waiving late filing penalty and interest September 26, 1997 Scarborough Tax Services Headquarters Group 471-1-2 A. ... If this course of action is taken, we suggest you obtain the trustee's concurrence to apply any refunds arising by reason of the cancellation of such assessments to the tax payable by the estate, if any, in respect of the same time period and that consideration be given under subsection 220(3.1) of the Act to waiving any late filing penalty or interest which would otherwise be assessed in respect of the tax payable by the estate. ...

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, CPP contributions paid in the year prior to the leave period must be taken into consideration by the trustee. ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year. ...

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, CPP contributions paid in the year prior to the leave period must be taken into consideration by the trustee. ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year. ...

The deemed proceeds of disposition is the fair market value of the restrictive covenant. 3- Yes Reasons: 1- Providing the transfer of the restricted covenant was made without valuable consideration there would be a gift and a receipt may be issued for the deemed fair market value set out in proposed subsection 110.1(4) or 118.1(12) of the Act. 2- Since the property comes into existence at the time of the agreement there is likely no cost or a nominal cost. ... Accordingly, the above provisions could apply providing that the transfer of the property, the restrictive covenant, by the land owner to the land trust is a gift (i.e., is a voluntary transfer of the individual’s or the corporation’s property without valuable consideration). ...

Finally, another consideration is how the excess land was used during the period of ownership. ... We would also note that it appears that no consideration was given, in the above circumstances, to the application of the rollover provisions of subsection 70(6) of the Act, upon the death of a spouse, and we have not been provided with sufficient information to establish whether these provisions apply. ...