Search - consideration

Proposed subsection 248(32) of the Act provides that the amount of the advantage is generally the value, at the time the gift is made, of any property, service, compensation or other benefit received, or expected to be received in the future by the donor or a person who does not deal at arm's length with the donor, as partial consideration for, or in gratitude for the gift. ...

However, proposed subsections 248(30) to (32) of the Act allow for the recognition of a gift for tax purposes in certain situations where a donor, or a person who does not deal at arm's length with the donor, receives consideration or other advantages for property transferred. ...

However, we have given consideration to whether each of these items would fall into paragraph (e) of class 12 as being "a medical or dental instrument" or in paragraph (h) of class 12 as being a "tool". ...

We recognize that the Act does not specifically define the cost of a life insurance policy and we have brought this to the attention of the Department of Finance for their consideration. ...

A would also sell the Debt to B for nominal consideration. Whether there would be tax consequences to B when B would receive payments on account of the outstanding principal amount of the Debt. ...

However, a cash gift paid from a corporation to an individual in his or her capacity as a shareholder, where no consideration is provided by the shareholder in return, would be a benefit to which subsection 15(1) of the Act would apply. ...

Taking this guidance into consideration, the CRA is of the view that, in applying the substantial requirement test: The size of the trade or business in the U.S. need not be "as large as" the income-generating activity in Canada; but it must be more than "a very small percentage" of the size of that activity. ...

Since the situation described in your correspondence deals with a completed transaction involving specific taxpayers and because we do not have sufficient information to conclusively determine whether all the conditions would be met for claiming a tax credit, any further consideration of this matter should be handled by the appropriate TSO. ...

The facts in your letter are briefly summarised as follows: You are employed as a XXXXXXXXXX and that your duties of employment typically require you to work 12-16 hours; Your employer's business primarily involves the transportation of XXXXXXXXXX on short and long haul trips; Your duties of employment take you away from the municipality where your employer's home terminal is located and where you report for work; You supply your own food and prepare your own meals during each work shift; and Subject to safety considerations, sometimes you are able to get some sleep during your work shift in an employer-provided bunk, even though you return home at the end of each shift. ...

Flaherty‚ Minister of Finance, for his consideration. I trust that the information I have provided is helpful. ...