Search - consideration

Based on US jurisprudence, a signing bonus arises from a unilateral contract representing one party's promise to pay money in consideration for another party's signature on a contract. ... The Queen, 95 DTC 871 (T.C.C.), the Court described an inducement payment as an amount granted in consideration of an obligation on the recipient's part. ... Canada, [1998] 1 S.C.R. 147, concerning the computation of profit, unless the inducement is of a capital nature because it can be viewed as consideration for the disposition of a capital property by the taxpayer. ...

As consideration for the transfer of the shares of the capital stock of CANCO, PUBCO will receive from Newco an interest bearing note (bearing a commercial rate of interest) with a principal amount equal to the FMV of the shares of the capital stock of CANCO (less a nominal amount equal to the value of the Preferred Shares issued as part of such consideration) and a nominal number of Preferred Shares. As consideration for the transfer of the shares of the capital stock of FORCO1, PUBCO will receive from Newco an interest bearing note (bearing a commercial rate of interest) with a principal amount equal to the FMV of the shares of the capital stock of FORCO1 (less a nominal amount equal to the value of the Preferred Shares issued as part of such consideration) and a nominal number of Preferred Shares. As consideration for the transfer of the loan receivable from FORCO1, PUBCO will receive from Newco an interest bearing note (bearing a commercial rate of interest) with a principal amount equal to the principal amount of the loan receivable from FORCO1 (less a nominal amount equal to the value of the Preferred Shares issued as part of such consideration) and a nominal number of Preferred Shares. ...

Position Adoptée: Part of the exploration expenses incurred should constitute a consideration for a right to a share of the seller. ... The administrative position stated in Interpretation Bulletin IT-125R4 with respect to the simple farm-out would apply with respect to the acquisition of the interest in the unproven resource property in consideration for the CEE that are not part of the consideration for the warrants. The property would not have an acquisition cost for the purchaser and the consideration for that part of the deal would be considered CEE if the expenses otherwise qualify. ...

No consideration other than the common Shares of Holdco will be received by Parentco on the transfer. ...

You ask what is meant by the phrase "an interest in a trust that was not acquired for consideration" and ask for further clarification of the rules relating to the property that is held in such a trust. A beneficiary's interest in a trust that is not acquired for consideration is an interest which the beneficiary acquired without payment or other transfer, assignment or disposition of property to any person in order to obtain such an interest. ... However, if a trust is established by contributions from two or more unrelated persons and those unrelated persons are beneficiaries of the trust, their respective interests in the trust would be considered to have been acquired for consideration. ...

XXXXXXXXXX (Consideration will be given to merging the XXXXXXXXXX Management Partnership and XXXXXXXXXX Management Partnerships at a future time. ... Alternatively, the XXXXXXXXXX Partners will transfer their interests in the XXXXXXXXXX Management Partnership to the XXXXXXXXXX Management Partnership in consideration for partnership interests pursuant to subsection 97(2) of the Act. ... The parties will agree to allocate to each of the XXXXXXXXXX Assets, as consideration therefor, such part of the aggregate consideration to be given by the XXXXXXXXXX Partnership for all the XXXXXXXXXX Assets as is equal to the fair market value of the particular XXXXXXXXXX Asset. 22. ...

A will acquire XXXXXXXXXX limited partnership units of the Partnership for a cash consideration of $XXXXXXXXXX. ... As consideration for the transfer of property described herein, the Partnership will: (c) assume the Property Debt; and (d) issue to Mr. ... A's Property Debt having a principal amount equal to the Cash Amount will be assumed by the Partnership as consideration for the transfer by Mr. ...

However, consideration may be given to the possible application of section 245 of the Act ["GAAR"],depending on the particular circumstances. 3. ... In this general reply, we do not know why the transferor would transfer assets for less than fair market value consideration. ... However, consideration may be given to the possible application of section 245 of the Act ["GAAR"], depending on the particular circumstances and the reason why the taxpayer agreed to only receive a nominal interest in the partnership when such an Excess existed. ...

Also on that date, XXXXXXXXXX also issued XXXXXXXXXX common shares in the name of XXXXXXXXXX for nominal consideration. 10. ... XXXXXXXXXX children will subscribe for the common shares of Newco for nominal consideration 19. ... The Estate will receive XXXXXXXXXX Class A shares and XXXXXXXXXX Class B shares of Newco as consideration for the transfer of its XXXXXXXXXX Class C shares (i.e. total value of consideration equal to $XXXXXXXXXX). ...

X has not commenced to use the surface right for the purpose of gaining or producing income therefrom in the absence of there being any income from a business or property- in this regard, consideration should be given to our comments regarding "carrying on business" which appear under the heading "Royalties". ... X is entitled to receive such a payment, he would be required to include the payment received in the calculation of his CCDE pursuant to subparagragh 66.2(5)(b)(v) of the Act after giving due consideration to whether a portion of the payment should instead be allocated to proceeds of disposition in respect of the surface right. ... X of the amount of the annual rent is nothing more than additional consideration for granting the profit a prendre to Mineco- not a true "rental" but rather a payment analogous to exercising an option- and should be included by Mr. ...