Search - consideration

To give effect to the Repayment, Corp A issued to Corp B XXXXXXXXXX Preferred Shares for an aggregate consideration of USD XXXXXXXXXX. 10. ... An amount of approximately CAD XXXXXXXXXX was added to the Stated Capital of the Preferred Shares, such amount representing the full amount of the consideration received by Corp A on the issuance of the Preferred Shares in USD converted to CAD, based on the Exchange Rate in effect at the time of the Repayment. 13. ...

Would the date of acquisition of the property by the deceased be taken into consideration? ... Est-ce que la date d'acquisition du bien par le défunt serait prise en considération? ...

Subsections 248(30) to (32) of the Act allow for the recognition of a gift for tax purposes in certain situations where a donor, or a person or partnership who does not deal at arm's length with the donor, receives consideration or other advantages for the property transferred. ... We would add that the Canada Revenue Agency generally does not recognize temporary transfers of property as gifts and a frequent consideration in determining whether a gift has occurred is whether the subject of the gift could revert to the donor. ...

The determination of whether or not an object has become sufficiently attached to the land (i.e. a fixture), requires the consideration of the: Degree of Annexation, and The Purpose of Annexation. The degree of annexation requires some substantial connection with the land or a building on it to be established, and a key consideration is whether the building can be removed from the land without injury to itself or to the land. ...

27 January 2014 External T.I. 2013-0504191E5 F- RRSP, qualified investment CRA Tags ITR 4900(14) ITR 4900(6) ITR 5100(1) 207.01 Principales Questions: 1) General questions regarding shares as a qualified investment for an RRSP trust. 2) For the application of subsection 207.05(1), is there an advantage in a situation where the annuitant of an RRSP trust who holds shares of a corporation uses an asset of the corporation for no consideration? ... Relativement à la notion d'avantage, vous désirez savoir si le fait que le rentier d'une fiducie REER utilise sans considération un bien d'une société dont la fiducie REER détient des actions représente un avantage au sens du paragraphe 207.01(1) de la Loi de l'impôt sur le revenu (« Loi ») Sauf indication contraire, tous les renvois législatifs dans la présente sont des renvois aux dispositions du Règlement de l'impôt sur le revenu (« Règlement »). ...

Reasons: (1) The foundation did not acquire for consideration more than 5% of the common shares of the corporation. (2) Based on the facts provided, the proposed transaction would not be considered an avoidance transaction. ... Rather, they adopted a value estimate that was based on an amount that the Foundation had determined it was willing to invest based on its consideration of the business case for commercialization of the Technology. ...

The following terms and taxpayers referred to throughout this document will have the following meaning: "Agreement" means the legal Reseller Agreement negotiated between Forco and Canco detailing the rights and conditions under which Canco agrees to sublicense the Custom Software to sub-licensees within Canada, as described in paragraphs 9 to 13; "Canco" means the proposed new corporation described in paragraph 7; "CRA" means the Canada Revenue Agency; "Custom Software" means XXXXXXXXXX; "Forco" means XXXXXXXXXX; "License Fee" means the one-time fee to be paid by Canco to Forco under the Agreement in consideration for each sublicense that will be granted by Canco. ... For greater certainty, the CRA has not considered, confirmed or made any determination in respect of: (a) any additional fees that may be contemplated under the Agreement; (b) any income tax considerations associated with Forco's branch operations in Canada; and (c) whether or not subsection 247(2) of the Act applies to any transactions between Forco and Canco as described in the facts or proposed transactions of this letter. ...

Malgré ces considérations particulières aux travaux en cours ayant fait l'objet d'un choix prévu à l'article 34 de la Loi, l'évaluation d'une participation dans une SP nécessite une analyse de l'ensemble des faits, circonstances et documents propres à chaque situation donnée particulière. ... Il est opportun de noter que les commentaires qui précèdent sont spécifiques à la considération de la valeur de travaux en cours d'une entreprise de professionnels ayant fait l'objet d'un choix prévu à l'article 34 de la Loi dans le contexte de l'évaluation d'une participation dans une SP. ...

Furthermore, it has been our long-standing position that the cost of a property received by a corporation from its shareholder for no consideration, for example as a capital contribution, would, in the absence of a specific provision of the Act to the contrary, result in the corporation having a cost of the property equal to its FMV. ... Thus, on the basis of all of the considerations presented above, it is our general view that the cost of property received by a Canadian corporate shareholder from its wholly-owned foreign affiliate on a return of capital should be considered to be equal to the FMV of the property at the time of the distribution. ...

By contrast to the common law meaning, proposed amendments to the Act provide for “split-receipting”, which may, in certain circumstances, allow a transfer of property to qualify as a gift for tax purposes where a donor has received consideration for property transferred to a qualified donee after December 20, 2002. ... In addition, the proposed amendments provide that the amount of the advantage in respect of a gift is generally equal to the FMV of any property, service, compensation or other benefits received, or expected to be received in the future, by the donor, or a person or partnership who does not deal at arm's length with the donor, that is consideration or in gratitude for, or in any other way related to the gift. ...