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, 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. ...

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.  In our view, the word "gift" has been interpreted as being a voluntary transfer of property without consideration and without conditions.  ...

The           24(1)       District Taxation Office subsequently disallowed those claims on the basis that the social assistance payments from the Ontario Ministry were "received" for the purposes of subparagraph 110(1)(f)(iii) by the Corporation rather than by the     19(1)      As paragraph 81(1)(h) of the Act has been recently enacted into law (Bill C-18),            19(1)              representative have requested consideration of whether the payments received by the   19(1)      in partnership from the Corporation are exempt under this provision. ... A further consideration is that paragraph 81(1)(h) refers to a "social assistance payment... made on the basis of a means, needs or income test to the extent that it was received directly or indirectly by the taxpayer for the benefit of another".  ...

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.  ...

As discussed in paragraph 3 of Interpretation Bulletin IT-339R2, a PHSP must be in the nature of insurance and must contain the following basic elements: i)      an undertaking of one person, ii)      to indemnify another person, iii) for an agreed consideration, iv)      from a loss or liability in respect of an event, v)      the happening of which is uncertain. ... With respect to your second question, provided the employees are not shareholders, the Department considers that, where a PHSP is self-insured (i.e., the consideration for the "insurance" is regarded as the employees' covenants in their contract of service with the employer), all employees (or all employees within a specific category) should be covered in one plan with the same coverage for each employee. ...

Nonetheless, we can comment that where a medical expense of the type under consideration is allowable, a deduction may be claimed for the purchase price of the equipment or, if applicable, for the cost of renting the equipment. ... Finally, we have forwarded a copy of your letter to our Current Amendments Division for their consideration in referring this matter to the Department of Finance, which, as you may know, is responsible for initiating amendments to the Income Tax Act and Regulations. ...

In the situation you describe, a corporation (operator) obtains the right to process the tailings (and ownership of the processed product), in consideration for a cash payment and an interest in the processed product (or cash equivalent to the value of the agreed percentage of the processed product) taken back by the owner of the mine. ... Under these circumstances, you have requested our opinion on whether: (a) the right sold by the original owner to the operator is a Canadian resource property as defined in subsection 66(15)(c) of the Act and (b) the interest in the processed product which forms part of the consideration taken back by the owner of the mine represents a source of resource profits to it, under Income Tax Regulation 1204(1)(b)(iii) or (b.1). ...

While number 11 of the proposed Application form indicates that this requirement will be met, we find the third paragraph under the caption "Tax Considerations" to be confusing in this regard and we suggest it be reworded to clearly reflect this requirement. 7. ... In line three of the last paragraph under the caption "Tax Considerations", we suggest that "employment" be inserted before "income". ...