Search - consideration

9 February 1990 Income Tax Severed Letter AC59439- Inadequate Consideration for Redemption of Shares Unedited CRA Tags 69(1)(b), 84(3) 5- 9439 19(1) S. ...

8 March 1990 Income Tax Severed Letter AC59601- Inadequate Considerations Unedited CRA Tags 69(1), 20(1)(c) 19(1) 5-9601 D.S. ...

2 July 1992 Income Tax Severed Letter 9207725- Inadequate Consideration Unedited CRA Tags 69(11) 920772 A.Y. ...

19 December 1991 External T.I. 9126915 F- Attribution of Gain to Transferor where Nil Consideration Unedited CRA Tags 74.2(1), 74(2), 73(1) 912691 Dear:19(1) Re: Application of Subsection 74.2(1) of the Income Tax Act (the Act} We are writing in reply to your letter of August 19, 1991, wherein you requested that we confirm your views on the interpretation of subsection 74.2(1) of the Act as it relates to the following situation. ...

7 October 1990 Income Tax Severed Letter- Consideration of Timber Quota Certificate and Timber Licence as Timber Resource Property Unedited CRA Tags 13(21)(d.1) Dear Sirs: Re: XXX "Timber Quota Certificate"/"Timber Licence") Paragraph 13(21)(d.1) of the Income Tax Act (the "Act") We are writing in reply to your letter of September 11, 1990, in which you request our interpretation of whether a "Timber Quota Certificate" and a "Timber License" constitute a timber resource property as defined in paragraph 13(21)(d.1) of the Act. ...

21 June 1994 Internal T.I. 9408087- TIMING CONSIDERATION TO A HOME RELOCATION LOAN Unedited CRA Tags 110(1)(j) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...

24 October 1990 External T.I. 9024635 F- Consideration of Timber Quota Certificate and Timber Licence as Timber Resource Property Unedited CRA Tags 13(21) timber resource property 24(1) 5-902463   C.K. ...

Income Tax Considerations Relating to the Inheritance Pursuant to subsection 70(5.2), when a taxpayer dies owning CRP, he is deemed to have disposed of the CRP immediately before death and to have received proceeds of disposition equal to its fair market value (“FMV”) at that time. ... Income Tax Considerations Relating to the Disposition of CRP The income tax consequences that arise on a disposition of CRP will depend on whether the CRP is an oil and gas property or a mineral property. ... Income Tax Considerations: When Mr. X died he would have been deemed to have disposed of the Property for proceeds of disposition of $1 million, in accordance with paragraph 70(5.2)(a) and the Taxpayer would have been deemed to have acquired the Property at a cost of $1 million pursuant to paragraph 70(5.2)(b). ...

There may also be isolated instances where consideration could be given to the cancellation or waiver of interest and/or the 6% penalty where the inability to pay appears to be of a permanent nature. ... General Policy Considerations Requests Involving Third Party Error The responsibility for meeting obligations under the legislation we administer (e.g. filing a timely and accurate return) rests with the client. ... However, if the client provides new information, the request may go back to the original decision maker for consideration, rather than to the committee. ...

Consideration Black's Law Dictionary defines consideration, in part, as follows. ... Thus, in a contract of sale, the money paid or agreed to be paid by the purchaser is the consideration to the vendor, and the property sold is the consideration to the purchaser. ... It is thus our opinion that these loan elements would not constitute consideration. ...