Search - consideration

In relation to this requirement, it is our view that the arrangement relating to health care coverage and the "group retirement plan" are interrelated and comprise one plan in relation to the consideration of whether a PHSP can be regarded as being in existence. ... However, the consideration would be whether the plan is a "retirement compensation arrangement" or other type of arrangement described in Interpretation Bulletin IT-502 and the related special release dated May 31, 1991 which have been enclosed for your reference. ...

Therefore, while we would agree that the fact the remainder interest was gifted to the unrelated person would warrant consideration in determining whether a non arm's length relationship existed, other factors relative to the circumstances of the particular transaction as discussed above would require equal consideration in making this determination. ...

(2)When a co-op customer receives shares of the co-op or equity in the co-op as consideration for the sale of product to the co-op, is the customer required to include the value of the shares or the value of the equity in income as sales revenue? ... Check-off Where a taxpayer receives a payment in kind as consideration for goods sold in the course of carrying on business, the taxpayer must include the full sales price of the goods in computing income from the business. ...

Our Comments As indicated in paragraph 3 of Interpretation Bulletin IT-110R2, a gift, for the purposes of sections 110.1 and 118.1, is a voluntary transfer of property without valuable consideration. A gift can be said to have been made where all of the following conditions are satisfied: (a)property (usually cash) is transferred by a donor to a registered charity; (b)the transfer is voluntary; and (c)no consideration or benefit accrues to the donor or to anyone designated by the donor as a result of the transfer. ...

The definition of flow-through share in subsection 66(15) of the Act requires that a share be issued to a person under an agreement in writing and subsections 66(12.6), (12.62) and (12.64) of the Act require that the person must have given consideration under the agreement to the corporation issuing the flow-through share. Paragraphs 66(12.6)(d), (12.62)(d) and (12.64)(c) of the Act limit the amount that may be renounced by a corporation to a flow-through shareholder to the amount of consideration received for the shares. ...

Should your client wish to pursue the matter at a later date, we would be pleased to resume consideration at that time. ... The PUC of the share would be equal to the cash consideration paid for the share. ...

Her address is: Merys Hughes Director PharmaCare Operations 1515 Blanshard Street Victoria BC V8W 3C8 Canada Yours truly, Daryl Boychuk, LL.B for Director Business and Partnerships Division Income Tax Rulings Directorate April 29, 2003 Vancouver Tax Services Office HEADQUARTERS Client Services Division L.Holloway, CA Loretta Bemister (613) 957-2104 Assistant Director 2003-001337 XXXXXXXXXX We are forwarding for your consideration and reply the attached letter from XXXXXXXXXX. ... Daryl Boychuk, LL.B for Director Business and Partnerships Division Income Tax Rulings Directorate April 29, 2003 Federal and Provincial Affairs Division HEADQUARTERS Income Tested and P/T Exchange of L.Holloway, CA Information Processes (613) 957-2104 Bob Searle A/Director Attention: Jyotsna Dalvi, Manager 2003-001337 XXXXXXXXXX We are forwarding for your consideration and reply the attached letter from XXXXXXXXXX. ...

Whether the reduced inclusion rate under paragraph 38(a.1) would apply to part of a capital gain realized by an individual on the donation of publicly traded securities to a registered charity if the individual receives partial consideration. ... Your second question is whether the reduced inclusion rate would apply to the "gift portion" of a capital gain realized by an individual in circumstances where the individual has donated publicly traded securities to a registered charity and receives an annuity as partial consideration. ...

Cette demande donnera généralement lieu à une nouvelle cotisation pour prendre en considération la déduction pour pertes. ... Le Ministre sera toutefois dans l'obligation d'émettre une nouvelle cotisation relative à l'an 01 de façon à prendre en considération le report de pertes tel que le prévoit le paragraphe 152(6) de la Loi. ...

In general, a "gift" for purposes of the Income Tax Act ("the Act") means a voluntary transfer of property without valuable consideration to the donor. Proposed amendments to the Act will allow the Canada Customs and Revenue Agency (CCRA) to recognize a gift, for tax purposes, in certain circumstances where a donor has received consideration for property transferred to a registered charity or other qualifying donee after December 20, 2002. ...