Search - consideration

Where a transaction or a series of transactions is carried out so that income is paid to a treaty resident in order to obtain the benefits of the particular treaty, and those benefits would not have applied in the absence of the transaction or the series of transactions, the CRA will give consideration to the application of the GAAR to disallow those treaty benefits. ...

For example, the CRA is of the opinion that if, when the loan is made by a lender, it is apparent that the borrower will not be able to repay the loan and/or provide reasonable security for repayment, the lender would have transferred property (cash) without having received sufficient consideration. ...

A response to a particular taxpayer request will require a consideration of all relevant facts and circumstances. ...

You also want to know if any consideration will be given to taxpayers who relied on the information from Industry Canada. ...

/ Is the reimbursement of travel expenses a payment in consideration for the sale or lease of goods or for services rendered? ...

Gross income, net income, capital investment, cash flow, personal involvement, and all other factors may be relevant considerations. ...

Raisons: Wording of the Act TABLE RONDE SUR LA FISCALITÉ DES STRATÉGIES FINANCIÈRES ET DES INSTRUMENTS FINANCIERS DU 9 OCTOBRE 2015 APFF- CONGRÈS 2015 Question 8 Distribution de capital à un bénéficiaire qui est aussi un créancier Le paragraphe 107(2) L.I.R. permet un roulement fiscal automatique des biens remis à un bénéficiaire canadien en considération de sa participation au capital d’une fiducie. ...

Whether the CRA is of the opinion that GAAR would apply in this particular situation taking into consideration the recent Tax Court of Canada decisions with respect to surplus stripping cases? ...

In that regard, we note that your email has been forwarded to the Assessment, Benefit and Service Branch for further consideration. ...

Severance payment is an expense made at the cessation of employment and does not represent consideration for services provided. ...