Search - consideration

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, CPP contributions paid in the year prior to the leave period must be taken into consideration by the trustee. ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year. ...

Position: Yes Reasons: After further consideration, the GAAR Committee reversed the position that it had taken in 9723463. ... These shares were acquired for nominal consideration at a time when the shares had a fair market value of $XXXXXXXXXX per share. ...

(C) It is our view that the consideration would be paragraph 118.2(2)(a) of the Act (the fees would have to be paid to a "medical practitioner" which is defined in subsection 118.4(2) of the Act). ... (B) The sole consideration received from the consultant for the payments was the medical services. ...

The bonus contribution and vacation pay contribution components as well as the Retirement Allowance Plan appear to be primarily motivated by tax deferral considerations and would likely constitute an SDA. ... However, the bonus contribution and vacation pay contribution components of the Supplemental Plan, as well as the Retirement Allowance Plan, appear to be primarily motivated by tax deferral considerations. ...

Subsection 248(30) of the Act is a relieving provision that generally states that the receipt of a benefit or consideration (advantage) will not, in and of itself, disqualify a transfer of property from being a gift to a qualified donee for income tax purposes. In general terms, an advantage is the total value of any property, service, compensation, use or any other benefit that a donor (or a person or partnership not dealing at arm’s length with the donor) is entitled to as partial consideration for, in gratitude for, or in any other way related to the gift. ...

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, CPP contributions paid in the year prior to the leave period must be taken into consideration by the Trustee.  ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year.  ...

Your concerns regarding business activities carried on by non-profit organizations relate to tax policy considerations.  While our Department is responsible for the administration of the Act, the Department of Finance is the appropriate authority to which to refer matters relating to tax policy considerations. ...

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, CPP contributions paid in the year prior to the leave period must be taken into consideration by the trustee. ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year. ...

As part of a negotiated property settlement it has been agreed that, by way of a series of transaction W's shares in Propco be acquired by H for cash consideration prior to a final divorce judgement. 4.      ... It is contemplated that H will transfer all his preferred shares in Propco to Wco and will take back, as sole consideration, redeemable preferred shares with a redemption value equal to the fair market value of the Propco preferred shares and a paid-up capital as defined in paragraph 89(1)(c) of the Act equal to the paid-up capital of the Propco preferred shares. 6.      ...

.), the full amount of the premiums have the quality of income when received and therefore are included in income of the issuer under section 9 of the Act, as the premiums represent consideration for the issuance of the obligations and are received regardless of the period of time that the debt is outstanding.  ... Thus the prime consideration, where there is a dispute about a system of accounting, is, in the first place, whether it is appropriate to the business to which it is applied and tells the truth about the taxpayer s income position and, if that condition is satisfied, whether there is any prohibition in the governing income tax law against its use.  ...