Search - consideration

It should be noted that where a taxpayer has loaned money at less than a reasonable rate of interest to a Canadian corporation of which he is a shareholder or has guaranteed the debts of such a corporation for no consideration, the loan or the guarantee will generally be considered not to have been given for the purpose of gaining or producing income. ...

13 September 1988 Income Tax Severed Letter 7-1821- Foreign affiliates Unedited CRA Tags 95(2)(a), 95(2)(f), Reg. 5907(1)(e) This is further to our (Anderson/Dalphy) telephone conversation of August 26, 1988 wherein you advised that the taxation years relevant to the matters presently under consideration are statute-barred and that notices of reassessment were not issued and waivers were not received. ...

28 November 1989 Income Tax Severed Letter 0-0292- Paragraph 66(15)(d.1)—agreement in writing—flow-through shares Unedited CRA Tags 66(15)(d.1) Background We received a ruling request which proposed the following: XXX The Law Subsection 66(12.6) permits a corporation that has undertaken pursuant to an agreement in writing ("Agreement") to incur CEE, to issue flow-through shares (all in accordance with specific conditions), to renounce such CEE to a person who has given consideration for such flow-through shares, provided amongst other things, that the corporation incurs the CEE to be renounced, between the day the Agreement was entered into and the 24th month after the end of the month that included that day. ...

The amounts of any such renunciations cannot exceed the consideration paid for the option. ...

It Should be noted that where a shareholder has guaranteed the debts of his corporation for no consideration, the guarantee will generally be considered not to have been given for the purpose of gaining or producing income. ...

As you are aware, a gift is a voluntary and gratuitous transfer of real or personal property without consideration. ...

However, Article XII(4) defines "royalties" to mean payments of any kind received as consideration for the use of, or the right to use, any copyright of... ...

Technically, there is nothing in the legislation that provides for the correction requested by 24(1) nor could we find anything in our files to indicate that consideration was previously given to a similar situation. ...

In such cases taxpayers are to submit complete details in writing and a copy of the deceased annuitant's will to the Chief of Verification and Collections in their local district taxation office for consideration. ...

We have also suggested other minor editing changes to the Project for your consideration as noted thereon. ...