Search - consideration

XXXXXXXXXX will issue to XXXXXXXXXX as consideration for the purchase of its common shares and redemption of its Class A preferred shares, Class B preferred shares and Class C preferred shares non-interest-bearing demand promissory notes having a principal amount equal to the fair market value of the common shares purchased ("XXXXXXXXXX") and equal to the redemption amount of the preferred shares redeemed ("XXXXXXXXXX"). 25.Following the wind-up of XXXXXXXXXX as described in paragraph 23 above, XXXXXXXXXX will then purchase for cancellation, at fair market value, its common shares and redeem and cancel its Class A preferred shares, Class B preferred shares and Class C preferred shares held by XXXXXXXXXX in two stages: (a)in the first stage, XXXXXXXXXX will purchase a sufficient number of common shares or part thereof which will result in a deemed dividend, pursuant to the provisions of subsection 84(3), equal to one half of XXXXXXXXXX capital dividend account immediately before that time, which XXXXXXXXXX will elect, pursuant to subsection 83(2), to have been paid from its capital dividend account; and (b)in the second stage, XXXXXXXXXX will purchase the balance of its common shares and redeem its Class A preferred shares, Class B preferred shares and Class C preferred shares held by XXXXXXXXXX. XXXXXXXXXX will issue to XXXXXXXXXX as consideration for the purchase of its common shares and the redemption of its Class A preferred shares, Class B preferred shares and Class C preferred shares non-interest-bearing demand promissory notes having a principal amount equal to the fair market value of the common shares purchased ("XXXXXXXXXX") and equal to the redemption amount of the preferred shares redeemed ("XXXXXXXXXX"). ...

The taxpayer received common shares as consideration and, from the date of transfer to the present time, the taxpayer has been the sole shareholder of the company. ... There would be no consideration received for this gift. This transfer of shares to the spouse will occur at their adjusted cost base, such that there would be no capital gain arising as a result of the gift. ...

A will receive non-share consideration of $500,000 and non-voting preferred shares of Bco with a paid-up capital of $1 and which will have a redemption amount of $300,000 and will be retractable over a period of five years. ... In the two situations described above, the retraction of the shares over a five-year period may result in tax consequences arising from the difference in value between the shares that are sold and the shares that are received as consideration therefor. 2.      ...

Consequently, although 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. ...

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. ...

You are of the view that, from a policy perspective, any safe income earned by the partnership during the stub period should attribute to the shares of CCo. received by ACo. as consideration for the transfer of the partnership interest. ... " We are of the opinion that where the partnership interest is transferred under the provisions of subsection 85(1) of the Act, at an agreed amount equal to the adjusted cost base of the partnership interest to the transferor immediately before the transfer, the safe income earned in the stub period will be attributable to the shares of the transferee received as consideration for the transfer. ...

As consideration for the assignment of his Interest, Mr. A receives a proprietary interest in the net revenues generated by the marketing corporation (the "New Interest"). ... An eligible capital property is defined, pursuant to paragraph 54(d) of the Act, to be "any property, a part of the consideration for the disposition of which would, if (the taxpayer) disposed of the property, be an eligible capital amount in respect of a business" (emphasis added). ...

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. ...

Eisner Client Assistance Directorate XXXXXXXXXX-     Principal Residence Exemption Pursuant to our telephone conversation on May 33, 1993, we are forwarding, for your consideration and reply, a request for an advance income tax ruling submitted on behalf of the above-noted individual (the Taxpayer) by XXXXXXXXXX As indicated in the attached reply to XXXXXXXXXX, the ruling requested cannot be granted since it essentially involves a period of time that has already elapsed. ... While this paragraph indicates that severance restrictions may be a relevant consideration in determining whether land in excess of 1/2 hectare is necessary to the use and enjoyment of a residence, these comments relate to residential lots. ...