Search - consideration

Accordingly, in general terms, a gift is a voluntary transfer of property without valuable consideration. ...

Where, at the time a share is issued, there is an accrued gain inherent in the share (for example, where the share is issued as consideration for an asset with an accrued gain which is transferred to a corporation on a tax-deferred basis under section 85), it is our view that such accrued gain will always be tainted for the purposes of subsection 55(2) of the Act. ...

We recently had further discussions with officials at the Department of Finance and after further consideration it is their view that the intention of the legislator was not to restrict the application of paragraph 810(1)(a) of the Regulations to PUBI of the non-resident insurer that is a qualified insurance corporation. ...

Any amount received by XXXXXXXXXX in consideration for such a transfer would be included in XXXXXXXXXX income and would be considered as a cost of the entitlement to receive such amounts to Newco. ...

Toutefois, dans l'examen du caractère raisonnable de ces honoraires, le temps que consacre la personne qui fournit les conseils ou les services ainsi que le genre de travail qu'elle effectue serait pris en considération. ...

DEPARTMENT'S POSITION There would be several factors that would have to be taken into consideration in deciding whether it was "reasonable to conclude that the property was acquired by the taxpayer to replace the former property. ...

Paragraph 4 of Interpretation Bulletin IT-334R2 gives the following explanation concerning "Gifts and Other Voluntary Payments": "Amounts received as gifts, that is, voluntary transfers of real or personal property without consideration, are not subject to tax in the hands of the recipient. ...

However, consideration may be given as to whether the amounts paid for part-time attendant care would qualify as a medical expense under paragraph 118.2(2)(b.1) of the Act. ...

Usually no additional consideration is payable on the exercise of the Special Warrants and any Special Warrants that are not redeemed or exercised by the expiry date are deemed to have been exercised in full at that time. ...

However, it should be noted that in applying subparagraph 5(a) of Article 13 of the Convention, consideration has to be given to property referred to in paragraph 4 of Article 13 of the Convention, whether or not such property is property in which the business was carried on. ...