Search - consideration

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, those 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 his 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 must be recorded by the trustee may not coincide with the earnings reported in box "C" for that particular year.  ...

For example, a tax-deferred basis may involve a situation in which A Co. transfers an asset to B Co. with which it does not deal at arm's length, receiving as consideration preferred shares, and both file elections under subsection 85(l).  ... A deemed dividend arising under subsection 84(3) on the redemption of the shares received as consideration in the above situation would not be added to either the accounting or accumulated profits of A Co. ...

Yours truly, for DirectorFinancial Industries DivisionRulings Directorate Question- Sale of work-in progress In an arm's-length transaction, Newco purchases the business assets of Oldco consisting of:-     accounts receivable-     fixed assets and equipment-     work-in-progress Consideration (the "Total Purchase Price") for these assets consists of:-     cash-     assumption of Oldco's accounts payable-     an agreement to pay an amount (if any) representing the profit portion of work-in-progress existing at the sale date It is assumed that no goodwill exists in Oldco's business, and therefore no portion of the Total Purchase Price represents an eligible capital expenditure. ... If, however, it is established that these payments, are consideration for the goodwill of Opco's business, then such payments would constitute eligible capital expenditures to Newco. ...

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.  ...

Situation 1 A joint venturer in an active business concern transfers 100% of his interest in such concern to a corporation in consideration for shares of such corporation. ... Such funds borrowed by Holdco are then released to the vendor in consideration of the share purchase. ...

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.  ...

In fact, the neutrality of tax considerations in setting up deferred income plans qualifying as RCAs is the main reason, in our views for the existence of the RCA legislation. 3-      Fourth paragraph.  ... Replace "than annual" with "that the annual" T4A-RCA and NR4/NR4A Filing Instruction 8-      The description of Box(E) is deficient because it neglects to mention both RCA's property dispositions for consideration less than fair market value and RCA's property acquisitions for amounts greater than fair market value. ...

The exclusion from the carved-out property rules, provided by paragraph 209(1)(c) of the Act, would not be met in this instance because the farmee's interest in the property was not acquired solely in consideration of his undertaking to incur Canadian exploration expense or Canadian development expense in respect of the property (i.e. the equipping costs taint the exclusion).       ... It is the Department's position, as outlined in paragraph 11 of Interpretation Bulletin 125R3, that to the extent that an owner of a resource property (the "farmor") transfers a part interest therein to another person "the farmee") in consideration of the farmee's agreement to incur exploration and development expenses on that property, the proceeds of disposition to the farmor and the acquisition cost to the farmee of the resource property will be viewed as being nil.       ...