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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. ...

Given the diversity of Canada’s aboriginal peoples, each ASC’s connection to and status in a religious denomination must be considered on a case-by-case basis with consideration to the structure and practices of the particular system of faith of his or her band or community. ... In our view, with consideration to IT-141R and Kraft, the XXXXXXXXXX population would likely constitute a congregation. ...

Before discussing tax considerations, I would like to comment on two of your observations about Internet telephone services. ... I am forwarding a copy of our correspondence to senior CRA officials for their consideration in future compliance activity reviews. ...

Accordingly, a rent normally refers to a payment that is consideration for the use or the right to use property for a term, whether fixed in time or otherwise determinable, after which the right of the grantee to the property and to its use reverts to the grantor. ... As you know, the OECD Model Convention defines royalties in paragraph 2 of Article 12 as "payments of any kind received as consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work, including cinematograph films, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience". ...

À l'appui de votre projet de cotisation, vous donnez les motifs suivants: We have considered that your RRSP "uses or permits to be used any property of the trust as security for a loan" i.e. the preferred shares of the COOP; We have considered that your RRSP "acquired a property for a consideration greater than the fair market value of the property at the time of the acquisition" i.e. the preferred shares of the COOP; We also have considered that your RRSP disposed of property for no consideration because it is our opinion that your investment in the preferred shares of the cooperative is a sham. ...

In XXXXXXXXXX, the taxpayer, in order to protect the property from creditors, transferred the legal title to the property for nominal consideration to a friend with the agreement that the legal title would be reacquired at a later time. ... In XXXXXXXXXX, the taxpayer reacquired the legal title to the property from her friend, also for nominal consideration, in accordance with the agreement. 4. ...

Where a lessor charges a lessee a nominal monthly amount for the use of its automobiles, the CRA will examine the consideration exchanged. ... In this regard, we are aware that it is not uncommon for the use of automobiles to be provided in exchange for non-cash consideration. ...

Although consideration should be given to the availability and quantum of support provided, a person is generally considered to be dependent on an individual if the individual has actually supplied necessary maintenance, or the basic necessities of life (food, shelter and clothing) to the person on a regular and consistent basis. ... In respect of personal tax credits and in consideration of the above, one or both parents may qualify for the amount for infirm dependants age 18 or older under paragraph 118(1)(d) of the Act. ...

Generally, a plan will be considered a superannuation or pension fund or plan where contributions have been made to the plan by or on behalf of an employer or former employer of an employee in consideration for services rendered by the employee and the contributions are used to provide an annuity or other periodic payments on or after the employee's retirement in consideration for his or her employment services. ...