Search - consideration

The consideration received by the corporate shareholder consists entirely of a note payable on a specified date after the end of the shareholder's taxation year. ... These proceeds of disposition are however, in the form of a note, so in your view, the corporate shareholder should be in precisely the same position for tax purposes as if it had sold the shares to a third party for similar consideration, and therefore, when calculating any gain realized on the redemption, should be entitled to a reasonable reserve under subparagraph 40(1)(a)(iii) in respect of the amount of his proceeds of disposition which are not due until after the end of the year. ...

10 February 1982 Income Tax Severed Letter RCT R2-8 Unedited CRA Tags 85(1), 85(1)(e.2) Decision Summary Reference: Paragraph 95(1)(e.2) Subject: Subsection 85(1) rollovers for less than fair market value consideration. ... In addition we may refuse to rule if the consideration is less than the fair market value of the transferred property at the time of the last significant purchase of shares of the corporate transferor. ...

Opco's consideration is a note for $800 and a preference share redeemable and retractable for $1. In our opinion, paragraph 15(1)(b) of the Act would apply to include an amount in Holdco's income as property has been appropriated from Opco for the benefit of Holdco to the extent of the excess of the fair market value of the asset transferred over the fair market value of the consideration received by Opco. ...

We have been requested by a purchaser to provide a ruling that paragraph 85.1(2)(d) will operate to deny the application of subsection 85.1(1) in a case where an acquisition is structured so that the vendor of a share of the target company will receive consideration consisting of a preferred share of the purchaser plus a warrant, and there will be no agreed allocation of this consideration to fractions of the sold share. ...

Consideration of requests of this nature involves an extensive and fully objective review of the facts of the particular situation, and a careful evaluation of the merits of the request to ensure fair and uniform application of established criteria. xxxxx Mary Evans, a departmental officer, is handling xxxxx file. ... I wish to assure you that she will receive the utmost consideration possible in the resolution of her case. ...

Consideration of requests of this nature involves an extensive and fully objective review of the facts of the particular situation by senior departmental officials in Head Office. ... I wish to assure you that you will receive the utmost consideration possible in the resolution of your case. ...

Consideration of requests of this nature involves an extensive and fully objective review of the facts of the particular situation, and a careful evaluation of the merits of the request to ensure fair and uniform application of established criteria. ... I wish to assure you that she will receive the utmost consideration possible in the resolution of her case. ...

7 November 1990 Income Tax Severed Letter- Sale of work-in-progress Unedited CRA Tags none Question- Sale of work-in progress In an arm's-length transaction, Newco purchases the business assets of Oldco consisting of: • accounts receivable- fixed assets and equipment- work-in-progress Consideration (the "Total Purchase Price") for these assets consists of: • cash- assumption of Oldco's accounts payable- an agreement to pay an amount (if any) representing the profit portion of work-in-progress existing at the sale date It is assumed that no goodwill exists in Oldco's business, and therefore no portion of the Total Purchase Price represents an eligible capital expenditure. ... If, however, it is established that these payments, are consideration for the goodwill of Opco's business, then such payments would constitute eligible capital expenditures to Newco. ...

Consideration of requests of this nature involve an extensive and fully objective review of the facts of the particular situation by senior departmental officials in Head Office. ... I wish to assure you that the pensioners will receive the utmost consideration possible in the resolution of their cases. ...

The process ensures that each request receives proper consideration. This review procedure takes a certain amount of time. ... I would like to assure you that they will receive the utmost consideration possible in the resolution of their case. ...