Search - consideration

Whether an amount received as a gift or prize is taxable is a question of fact which can only be determined by analyzing all of the circumstances in a given situation Generally, however, amounts received as gifts (that is, voluntary transfers of real or personal property without consideration) or prizes are not subject to tax in the hands of the recipient. ...

Whether a particular amount is an advance on account of future earnings or a bona fide loan is a question of fact to be determined after consideration of all the relevant circumstances. ...

In your letter you indicate that subsection 148(8) of the Act provides for a tax free rollover on the disposition of a policyholder’s interest in a life insurance policy where, inter alia: (a) the policyholder’s interest in such a policy is transferred to the policyholder’s child for no consideration, and (b) a child of the policyholder or a child of the transferee is the person whose life is insured under the policy. ...

In consideration of the Insurer making such payments, the Plaintiff settles XXXXXXXXXX claim against the Defendant. ...

In consideration of the XXXXXXXXXX making such payments, the Plaintiffs settle their claims against the Defendants and the insurers of XXXXXXXXXX will not, however, be released and discharged from making such payments and each payment shall to the extent thereof and only to that extent, operate as a pro tanto release and discharge of the obligation to make such payments. 7.XXXXXXXXXX proposes to fund its obligations to make the payments in 5 above by the purchase of an annuity contract issued by XXXXXXXXXX The annuity contract will be non-commutable, non-assignable and non-transferable. 8.The owner and annuitant (beneficiary) under the annuity contract will be the XXXXXXXXXX however, an irrevocable direction will be executed in respect of the annuity contract directing the issuer to make the payments directly to XXXXXXXXXX or XXXXXXXXXX legal representative, or XXXXXXXXXX estate, as the case may be. 9.You have advised and you confirm to the best of your knowledge that none of the issues involved in this ruling request is being considered by a Tax Services office or a Tax Centre in connection with a tax return already filed and none of the issues is under objection. ...

Consideration would also need to be given to other factors such as the number of transactions, the resources used or time involved, and the intensity of the activity, i.e., is the farmer merely interested in cleaning up the blown trees and gaining a few dollars or is he accelerating the activity to the extent, that one would think that he is out to carry on a separate firewood business. ...

In our view, since, because of this circularity, it cannot be conclusively determined that Company C is a wholly owned corporation with respect to Company A, Company B is not a wholly owned corporation with respect to Company A. 2.Whether a taxpayer desires to confer a benefit on a related party is a question of fact that can be determined only after consideration of all the facts and circumstances. ...

PROPOSED TRANSACTION 17.Managementco #1 will enter into an administrative services agreement (the "Agreement") with Canco pursuant to which, in consideration of certain reasonable fees, Canco, as an independent contractor, will provide the following, and only the following services: (a) XXXXXXXXXX (b) XXXXXXXXXX (c) XXXXXXXXXX (d) XXXXXXXXXX (e) XXXXXXXXXX (f) XXXXXXXXXX (g) XXXXXXXXXX (h) XXXXXXXXXX (i) XXXXXXXXXX (j) XXXXXXXXXX (k) XXXXXXXXXX 18.Managementco #1 will itself continue to provide all other administrative and clerical services currently provided to Foreignco. ...

In consideration of the Casualty Insurer making such payments, the Claimant settles XXXXXXXXXX claim against the Defendant. ...

In consideration of Insurer B making such payments, the Claimant settles XXXXXXXXXX claim against the Defendants. ...