Search - consideration

Position: To the extent the fee represents consideration for items described within subparagraphs 212(1)(d)(i),(ii) and (iv), and does not represent consideration for copyright in subparagraph 212(1)(d)(vi) the fee will, subject to the U.S Treaty, be subject to withholding. ... Our Comments At the outset, we believe the application of paragraph 212(1)(d) of the Act in these circumstances depends on whether the PLF is characterized as consideration for the Procurement Rights or as additional consideration for the Franchise Rights. ... In our view, those obligations are consideration for the grant and the continued use of the Franchise Rights. ...

The CANCO4 Shares are all owned by CANCO1, having been purchased from an arm's length party on XXXXXXXXXX for a cash consideration of $XXXXXXXXXX. ... Each asset which comprises the division will be transferred in exchange for consideration equal to its fair market value. b. ... A will transfer the CANCO1 Subsidiary shares to SUBHOLDCO3 for consideration consisting of preference shares of the capital stock of SUBHOLDCO3 with a fair market value and a redemption amount equal to the fair market value of the CANCO1 Subsidiary shares. a. ...

8 December 1981 Income Tax Severed Letter RCT 85-075 F Unedited CRA Tags 85 RE:     Your memo of October 23, 1981 It is our opinion that in the situation which you described in your above-noted memorandum, the preference shares taken back as part of the consideration under a section 85 rollover would not be considered to be non-share consideration for the purpose of determining the transferor's proceeds of disposition. ...

We are satisfied that the employer request for extension warrants consideration and we are prepared to recommend acceptance. Your favourable consideration of this matter is requested. Yours sincerely, C. ...

For greater certainty, no non-share consideration will be paid by A Holdco in respect of the transfer of the shares so acquired by it. ... For greater certainty, no non-share consideration will be paid by B Holdco in respect of the transfer of the shares so acquired by it. ... For greater certainty, no non-share consideration will be paid by C Holdco in respect of the transfer of the shares so acquired by it. ...

On incorporation, Real Co subscribed for at least one Common Share of each of the Real-Subcos for nominal consideration. ... On incorporation, TC3 subscribed for at least one Common Share of each of the TC3-Subcos for nominal consideration. ... Real Co will transfer to TC3 all of its Common Shares of each of the Real-Subcos in consideration for Common Shares of TC3. 23. ...

Management received the Rollover Consideration and the other Holders received cash. ... Parent subscribed for common shares of Shareholder 5 in consideration for $XXXXXXXXXX. 9(L). ... Bidco subscribed for common shares of Buyerco in consideration for approximately $XXXXXXXXXX. 10. ...

Subsection 168(1) required the company to pay the GST on the earlier of the day that the consideration for the supply was paid, and the day that the consideration for the supply becomes due. Subsection 152(1) deems consideration for a taxable supply to become due on the earliest of three events. In the instant case, the provisions of paragraph 152(1)(a) apply to the extent of the earlier of the day that the supplier first issued an invoice in respect of the supply for that consideration or part and the date of that invoice. ...

Reasons: The fact that the only consideration paid by the individual for a home is the assumption of an existing mortgage does not in itself preclude the individual from qualifying for the HBTC if all the conditions for the credit are met. ... You want to know if you and your spouse will be eligible for the HBTC if you acquire a home that is subject to a mortgage and the only consideration given is the assumption of the mortgage from the previous owner. ... The fact that the only consideration paid for a home is the assumption of an existing mortgage does not in itself prevent you and your spouse from qualifying for the HBTC. ...

Under the terms of the PNG Lease, for the consideration specified therein the lessor has, inter alia, granted and leased exclusively unto the lessee all the leased substances, subject to the royalties reserved, as well as additional rights including "XXXXXXXXXX". ... All consideration for entering into the PNG Lease was payable to the lessor within XXXXXXXXXX days of the date thereof. ... As the property that is the subject of the PNG Lease is described as "all mines and minerals" in the subject land and the lessor has specifically granted to the lessee "the exclusive right and privilege to explore for, drill for,... leased substances" which is defined to include "all petroleum, natural gas and related hydrocarbons", we believe that the consideration received by the lessor for entering into the PNG Lease (i.e. the bonus and lump sum rental payments) represent amounts received by the lessor in respect of the disposition of a Canadian resource property. ...