Search - consideration

While complete information in this regard has not been provided, the available information suggests that since paragraph 54(13)(b) of the Compensation Act was involved, one consideration is whether the payment (or a part thereof) is income for the purposes of paragraph 56(1)(v) of the Act which deals with workers' compensation. ... In the case of the first consideration, part of paragraph 56(1)(v) of the Act, refers to "compensation received under an employees' or workers' compensation law of Canada or a province in respect of an injury... ...

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. ...

Where shares are exchanged for new shares which have a total value equal to those of the exchanged shares, and the shareholder receives no other consideration for the exchange, subsection 7(1.5) deems the new shares not to be acquired, the new shares to be the exchanged shares, and no disposition or exchange of the exchanged shares to have taken place. ... Subsection 85(1) of the Act Subsection 7(1.5) applies, as noted above, where shares are exchanged for new shares which have a total value equal to those of the exchanged shares, and no other consideration is received. ...

It is also our view that any consideration in the form of shares or debt of a corporation received by the individual farmer as a result of the transfer of the GRIP amount to his corporation may constitute a security in satisfaction of an income debt, within the meaning of subsection 76(1) of the Act.  Consequently, the value of this consideration would be includable in computing the income of the individual farmer in the taxation year in which he would transfer the right to receive the GRIP amount.  ...

In essence, the question to be answered is whether family considerations drove how the corporation acted rather than commercial considerations. ...

A transfer of property to a registered charity is not a gift for the purposes of section 118.1 of the Income Tax Act (the "Act") if there is consideration of any kind being received in return. The word "gift" has been interpreted by the Department as being a voluntary transfer of property without consideration and without conditions. ...

In the situation described by you, we would look to other factors to determine whether, in fact, there is fair consideration received from X Co. for the use of the vehicles in year five. This consideration may take a myriad of forms such as, a commitment or obligation to renew existing and perhaps future leases with the lessor, an agreement by X Co. to provide the leasing company with financing to acquire vehicles or future vehicles to be leased, it may be in the form of other services to be provided by X Co. ...

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. ...

Whether an adoption-in-fact has taken place is indeed a question of fact and such a determination would have to be made upon consideration of the circumstances. ... The "adopting" parent would appear to be eligible for consideration for the claim under paragraph 118(1)(a) but not for the equivalent claim under paragraph 118(1)(b), since it would not be likely that at a time when that parent was single he or she was supporting the child in a self-contained domestic establishment in which that parent was also residing. ...