Search - consideration

Therefore we have referred the problem to the Department of Finance for their future consideration. ... A disposition of the old options will occur and the new options will be received as consideration. ... In consequence, we have referred the problem to the Department of Finance for their future consideration. ...

The following is a summary of the relevant considerations regarding this exemption: In order to qualify as the principal residence of a taxpayer for a taxation year, a housing unit, including a cottage, must have been “ordinarily inhabited” in the year by the taxpayer, the taxpayer’s spouse or former spouse, or the taxpayer’s child. ... With respect to the latter issue, personal factors may also come into consideration that would look beyond pure economics. ... In the event that it is decided not to claim the principal residence exemption in respect of the sale of the cottage, another consideration is whether a capital gains reserve can be claimed. ...

We understand that the deceased taxpayer sold her entire farming operation to her daughter and as part of the sale, cattle and feed inventory was transferred to the daughter in consideration of a promissory note in the amount of $XXXXXXXXXX. ... On the contrary both the Bill of Sale and the Purchase and Sale Agreement refer to the promissory note as the consideration given for the transfer of the inventory. ... As the promissory note was received as consideration for the inventory transferred and accepted as absolute payment, there is no amount owing on the sale of the cattle and feed inventory. ...

X for cash consideration by a purchaser corporation (the “Parent”). Target is then wound up and the Parent wishes to “bump” the shares of Newco acquired on the wind-up. ... Newco will acquire the Property from Target during the course of the preliminary transactions, and will issue shares to Target in consideration for those assets. ... Issue You request our confirmation that, for purposes of clause 88(1)(c)(vi)(B) of the Act, the Property transferred to Newco by Target would not be property acquired by Newco in substitution for the Newco shares issued to Target in consideration for such property. ...

The Plaintiff alleged in the claim that the Defendant issued malicious and false opinions which resulted in the Plaintiff being eliminated from consideration for employment by another group of employers. ... The most common considerations can be the extent that a settlement can be regarded as being in the nature of employment income or a retiring allowance, which are taxable, or non-taxable personal damages. ... However, as indicated above, the reasonableness of an allocation within a settlement is also a consideration. ...

When a taxpayer disposes of both depreciable and non-depreciable property for a lump sum, the part of the consideration which can reasonably be regarded as being consideration for the depreciable property will be deemed to be its proceeds of disposition. However, whether the consideration for the depreciable property is "reasonable" is a question of fact, and in order to make such a determination, it is necessary to review all the facts surrounding a particular situation. ... However, where the total sale price does not exceed the fair market value of comparable land, it may be reasonable to conclude that the sale was essentially one of land and that the price was in consideration only of land. ...

Pursuant to proposed paragraphs 80(2)(g) and 80(2)(g.1) of the Act: (g) where a corporation issues a share (other than an excluded security) to a person as consideration for the settlement of a debt issued by the corporation and payable to the person, the amount paid in satisfaction of the debt because of the issue of the share shall be deemed to be equal to the fair market value of the share at the time it was issued; (g.1)where a debt issued by a corporation and payable to a person is settled at any time, the amount, if any, that can reasonably be considered to be the increase, as a consequence of the settlement of the debt, in the fair market value of shares of the capital stock of the corporation owned by the person (other than any shares acquired by the person as consideration for the settlement of the debt) shall be deemed to be an amount paid at that time in satisfaction of the debt; Under these proposed provisions a corporate debtor is considered to have paid an amount in satisfaction of a debt equal to the fair market value of a share, where that share is issued by the debtor as consideration for the settlement of the debt. Pursuant to proposed paragraph 80(2)(g.1) of the Act, a corporate debtor is considered to have paid an amount equal to the increase in value of the shares of the capital stock of the debtor that are owned by the creditor (other than those shares issued as consideration for the settlement of the debt) to the extent that the increase in value is as a consequence of the settlement of the debt. ...

In exchange for their shares of XYCo, X receives only shares of Amalco and Y receives a nominal amount of shares of Amalco and non-share consideration. ... The provisions of subsection 87(4) of the Act will not apply to Y since Y received consideration other than shares of Amalco. ... In exchange for their shares of XYCo, X and Holdco receive only shares of Amalco and Y receives a nominal amount of shares of Amalco and non-share consideration. ...

You expressed the view that the foundation would, by virtue of subsection 149.1(12) of the Act, be deemed not to have acquired control of the corporation since it has not given any consideration for the shares. ... However, on the acquisition of the common shares by virtue of the conversion of the preferred shares to common shares, the foundation would be providing the preferred shares as consideration. ... Thus, the acquisition of control by a foundation of a corporation would not automatically result in the foundation's registration being revoked; however, it could very well lead to that result following consideration of the relevant facts. ...

No valuable consideration- no benefit of any kind- to the donor or to anyone designated by the donor may result from the payment. ... Since the contributor has received consideration in return for his contribution, no gift has been made. ... A donation of property to a registered charity is not a gift for the purposes of the Act if there is consideration of any kind being received in return. ...