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As further discussed in 10c and 10d below, under the authority of the Articles of Amendment as described above, Continuing Fund will issue its Class A shares to Terminating Fund as consideration for the purchase of Terminating Fund's assets (these are the "Merger Shares") which will be immediately thereafter transferred and distributed to the Class A shareholders of Terminating Fund under the Merger redemption procedure referred to in 10a above. ... As consideration for the Assets, Continuing Fund will issue the Merger Shares to Terminating Fund. ...

On XXXXXXXXXX, Brother entered into a purchase and sale agreement, as vendor, to sell the Old Property to XXXXXXXXXX ("Purchasers") for consideration of $XXXXXXXXXX, with a closing date of XXXXXXXXXX. ... The incidents of a landlord-tenant relationship generally include rent, a contract for consideration and reversion of the property in the landlord. ...

18 February 2010 Internal T.I. 2009-0325831I7- SR&ED proxy method- overhead outside Canada Unedited CRA Tags 37(1.4), (1.5) Principal Issues: Whether the amount deemed by subsection 37(1.4) of the Income Tax Act should be taken into consideration in calculating the prescribed proxy amount under subsection 2900(4) of the Income Tax Regulations. ... OUR COMMENTS We are of the view that the amount deemed by subsection 37(1.4) of the Act should be taken into consideration in calculating the PPA in subsection 2900(4) of the Regulations based on a textual, contextual and purposive analysis of subsection 37(1.4). ...

In this regard, particular consideration must generally be given to the following factors: the nature of the duties to be performed by the employee (certain types of work are, by their nature, short term engagements, such as repair work or trades which are involved only during a certain phase of a project); the overall time estimated for a project, or a particular phase of a project, on which the employee is engaged to perform duties; and the agreed period of time for which the employee was engaged according to the employment contract or other terms of the engagement. The original intent of the parties as to whether the employee's duties at a particular work site will be of a temporary nature will be an important consideration and one of the best indicia of such intent would be to refer to the terms of the particular employment contract. ...

As further discussed in 5c and 5d below, under the authority of the Articles of Amendment as described, Continuing Fund will issue its Class A shares to Terminating Fund as consideration for the purchase of Terminating Fund's assets (these are the "Merger Shares") which will be immediately thereafter transferred and distributed to the Class A shareholders of Terminating Fund under the Merger redemption procedure referred to in 5a above. ... As consideration for the Assets, Continuing Fund will issue the Merger Shares to Terminating Fund. ...

In a typical PNG Lease, the owner of the mineral rights (the "lessor") grants the oil and gas company (the "lessee") the exclusive right to explore for, drill for and take the petroleum, natural gas and related hydrocarbons that occur on or under a particular parcel of land in return for consideration consisting of lump sum rental payments and bonus payments. Since a "Canadian resource property" is defined in subsection 66(15) of the Act as including any right, licence or privilege to explore for, drill for or take petroleum, natural gas or related hydrocarbons in Canada, we believe that the consideration received by the lessor for entering into a PNG Lease should be treated as proceeds of disposition of a Canadian resource property. ...

However, we are seeing an increasing number of transfers of the "management right" to the list from one representative to another representative in the same brokerage firm, for consideration. ... At all times, the ultimate cost of the consideration given to the departing representative is born by the other representative who is acquiring the right to manage the new client list. ...

CRA Response Paragraph 7(1)(b) of the ITA provides that, if an employer has agreed to issue its shares to one of its employees, the employee who has transferred or otherwise disposed of rights under the agreement to a person with whom he was dealing at arm's length, is deemed to have received, because of his employment and in the taxation year in which he made the disposition, a benefit equal to the amount, if any, by which the value of the consideration for the disposition exceeds the amount that he has paid to acquire those rights. ... The ITA does not provide for any deduction in computing the employee's income if the consideration for the disposition of his options is a debt receivable from the employer. ...

Évidemment, le poids à accorder aux divers éléments ou facteurs qui doivent être pris en considération pour déterminer si un couple de sexe différent forme une union conjugale variera grandement, presque à l'infini. ... De plus, comme l'ont souligné les juges de la Cour suprême du Canada, le poids à accorder à chacun des éléments en considération peut varier d'une situation à l'autre. ...

Le paragraphe 41 mentionne que l'imminence du décès devrait être prise en considération ainsi que la possibilité que l'assuré recouvre la santé et ne meurt pas. ... Assuming that the fair market value of the policy is determined by a qualified actuary, taking into consideration the factors indicated above, is the CRA of the opinion that the charity may issue a receipt for an amount equal to this fair market value, even if it exceeds the cash surrender value of the policy? ...