Search - consideration

The question under consideration is the taxability of the interest on the excess contributions. ... In the unusual circumstance that the above considerations do not apply, it would seem that the income would be subject to tax; likely as the income of a trust. ...

You indicated that a stock appreciation right permits an employee, at his option, to use the appreciated value of his stock options to acquire shares from the employer corporation for no consideration other than giving up his stock options. ... Where the fair market value of the shares increases to $20, the employee could, instead of exercising the option for 100 shares at $10 each, exercise the stock appreciation right and acquire 50 shares for no consideration other than giving up the stock option (i.e. 100 x $10 appreciation in value divided by $20 fair market value). ...

As long as the value of the shares which are received by each spouse as consideration for their interest in the farms land is equal to the value of the interest in the farm land transferred by each spouse to the corporation paragraph 85(1)(e.2) will not apply. The fact that the interest in the farm land owned by the taxpayer's spouse may have been acquired by her from the taxpayer for no consideration does not affect the applicability of paragraph 85(1)(e.2). ...

Due to the elected amount and the amount of non-share consideration received on the transfer these preferred shares have a cost of nil pursuant to paragraph 85(1)(g) of the Act. 2. ... No consideration other than common shares will be received on the conversion. ...

In our view, the cost of a property to the purchaser is equal to the value of the consideration paid for it. Where a part of the purchase price is represented by a promissory note that is to be paid at a future date the amount of that part of the consideration involves a valuation problem. ...

As indicated in our letter we also advised that, as the other issues were payroll matters, we were forwarding the request for a ruling on to you for consideration. ... He further states, "however, I do think that the place where the benefits are paid to the plaintiff should be a consideration when assessing the situs for the benefits, based on Dickson, J.'s comments in NOWEGIJICK". ...

Major (613) 995-1178 May 5, 1983 Dear XXXX This is in reply to your letter of February 23, 1983 in which you requested our comments on certain questions which have arisen in your consideration of "butterfly" transactions and paragraph 55(3)(b) of the Income Tax Act (the Act). 1. ... For the purposes of those subsections the wind-up is considered to have commenced after the rollover of assets, pursuant to the provision of subsection 85(1) of the Act, to the transferees or their intermediary companies and the redemption of the shares taken back in consideration on those rollovers. 55(3)(b) 2. ...

Symes (613) 957-2110 February 10, 1988 Dear Sirs: Re: Subparagraph 40(2)(g)(ii) of the Income Tax Act (the "Act") This is in reply to your letter of December 1, 1987, in which you requested our interpretation with respect to the application of subparagraph 40(2)(g)(ii) of the Act to a loss from the disposition of an interest bearing debt acquired by a taxpayer as consideration for the disposition of capital property to a person with whom he does not deal at arm's length. ... The individual would receive as the sole consideration for the transfer an interest bearing demand loan in the amount of $2 million. ...

In addition, information (usually in the form of a plan document, pamphlet or booklet) concerning the plan for distribution to the eligible employees detailing the benefits available to the participants should also be submitted for our consideration. ... If you intend to resubmit the plan for our consideration you may wish to request an advance income tax ruling, provided the plan has not already been put into effect, in the format set out in Information Circular IC 70-6R. ...

We concur that, in Situation 1, the acquisition of a beneficial interest in the trust by the Contributor at the time of settlement would not disqualify the trust as a personal trust, because there was no consideration given by the Contributor for this interest in the trust. ... We also concur that, in Situation 2, the acquisition of a beneficial interest in the trust by the settlor at the time of settlement would not disqualify the trust as a personal trust, because the definition of a personal trust includes a provision which deems the settlor to have acquired his beneficial interest for no consideration. ...