Search - consideration

Subsection 86(2) of the Act does not apply if the fair market value of the preferred shares received as consideration for the disposition of the common shares, referred to as the "old shares" for purposes of section 86, is equal to the fair market value of the new shares. ...

Paragraph 4 of IT-491 sets out some factors that may be taken into consideration when determining the main or chief use of a property. ...

7 September 1991 Income Tax Severed Letter- RRSP Contributions Unedited CRA Tags 60(j.2) Subject: RRSP Contributions Pursuant to our telephone conversation with you on August 21, 1991, we are referring the enclosed correspondence for your consideration. ...

Dear Sirs: Re: Interpretation of the Definition of "Taxable Preferred Share" in Subsection 248(1) of the Income Tax Act (the "Act") This is in reply to your letter dated June 13, 1990, whereby you requested our opinion concerning our interpretation of paragraph (b) of the definition of "taxable preferred share" in subsection 248(1) of the Act, in a situation which you described as follows: XXX You requested our opinion as to whether a XXX could be considered to be a "taxable preferred share" by virtue of clauses (b)(i)(A) or (C) of the definition of that expression in subsection 248(1), and whether the phrase "it may reasonably be considered having regard to all the circumstances" in that definition provides any latitude in the applicability of the dividend entitlement clauses under consideration. ...

Paragraph 74.5(1)(b) is similar to subsection 74.5(2) in that where the consideration for a transferred property includes indebtedness to the transferor, the income from that transferred property which would otherwise be subject to attribution will only be exempt from attribution if the loan bears an appropriate rate of interest and the interest on that loan is paid within 30 days after the end of the taxation year in which it was payable. ...

You have submitted for our consideration the following hypothetical situation: Hypothetical Situation: • Limited Partnership A (“Partnership”) is a Limited Partnership which carries on the business (in Canada) of mining, processing and sales of the processed product. • Partnership is owned as to 60% by a German resident individual, Mr. ...

As a result, it is our view that, in addition to disallowing a deduction in respect of the benefit where the relevant corporation has no laid out cost (i.e. shares were issued from treasury), paragraph 7(3)(b) of the Act disallows laid out costs incurred with respect to the benefit under any agreement to sell or issue shares to an employee of a corporation or to sell or issue shares of a non-arm's length corporation at less than fair market value or for no consideration. ...

McKenzie, Chief of Audit of the Vancouver District Office for his consideration and assistance in ensuring that your plan is administered correctly and we would expect that an officer of his staff will contact you shortly. ...

Whether bona fide arrangements were made at the time the housing loan was made, for repayment of that loan within a reasonable period of time, is a question of fact that can only be determined upon consideration of all the circumstances of a particular taxpayer's case. ...

The wording of the trust agreement (page 1), XXX As indicated in paragraph 5 of IT-374, a contribution equals the excess of the fair market value of the property over the fair market value of the consideration given. ...