Search - consideration

The POD is equal to the consideration received, in this case the total of cash and the market value of shares acquired in exchange for the claim. 2. ... In exchange for the mining claim, Canco receives as consideration cash and common shares of the mining company. ... The expression “sale price” is not defined in the Act, but is generally accepted to mean the actual value of all consideration received by a seller from a buyer, including cash, property and/or the assumption of liabilities. ...

Our Comments Subject to certain conditions and limits, section 20.01 of the Income Tax Act (the "Act") allows a sole proprietor to deduct as a business expense amounts paid as a premium, contribution or other consideration under a PHSP in respect of the sole proprietor, his or her spouse or common-law partner, or members of his or her household. ... Therefore, it must represent (i) an undertaking by one person, (ii) to indemnify another person, (iii) for an agreed consideration, (iv) from a loss or liability in respect of an event, (v) the happening of which is uncertain. ... However, a cost-plus plan under which the administrator agrees to reimburse the sole proprietor, his or her spouse and members of his or her household for actual medical and hospital expenses and receives, as consideration, an amount equal to the amount reimbursed plus an administrative fee, does not qualify as a PHSP since it does not contain the necessary elements of insurance. ...

Provided a minimum of XXXXXXXXXX travelers are confirmed on a particular excursion, as consideration for the foregoing services, the Company will pay the travel costs on behalf of one tour host. ... Generally, an amount paid to an individual as consideration for services rendered will be taxable either as income from an office or employment or as income from a business depending on the particular circumstances. ... Accordingly, the value of all consideration received for services provided to the Company should be treated as business income. ...

There were no additional fees or charges in addition to the $20 per month, nor were there any commitments (e.g. a commitment to lease future vehicles from the lessor) between the Employer and the Lessor in consideration for the nominal $20 per month charge. ... (emphasis added) Where a lessor charges a lessee a nominal monthly amount for the use of its automobiles, the CRA will examine the consideration exchanged. ... We are aware that it is not uncommon for the use of automobiles to be provided in exchange for non-cash consideration. ...

CRA will examine the true consideration exchanged. If the amount paid is not grossly deviant from the fair market value of the automobile at the time of the purchase, then it is acceptable for the nominal amount paid to be used as the cost of the automobile for the purposes of the standby charge calculation. Reasons: CRA will examine the true consideration exchanged. In an arm's length transaction where a lessor has recovered a substantial value of the automobile from the lease arrangement, then the nominal amount paid to purchase the automobile should reasonably represent its fair market value. ... The cost of the automobile is also described in subsection 6(2) of the Act under variable C which states: C is the cost of the automobile to the employer where the employer owns the vehicle at any time in the year; Where a lessee purchases an automobile from a dealership at a nominal amount, the CRA will examine the true consideration exchanged. ...

The terms of the Partial Settlement Agreement and Release provide among other consideration, for the payment to the Plaintiff of: XXXXXXXXXX monthly payments of $XXXXXXXXXX, without indexation, commencing on XXXXXXXXXX, and continuing on the XXXXXXXXXX day of XXXXXXXXXX thereafter through XXXXXXXXXX, plus XXXXXXXXXX monthly payments of $XXXXXXXXXX, without indexation, commencing on XXXXXXXXXX, and continuing on the XXXXXXXXXX day of XXXXXXXXXX thereafter through XXXXXXXXXX. ... In consideration of the Insurer making the Structured Payments (and the Insurer providing certain non-structure consideration called for in the Partial Settlement Agreement and Release), the Plaintiff has agreed to settle the past Attendant Care claims against the Insurer. ...

When the plan represents (i) an undertaking by one person, (ii) to indemnify another person, (iii) for an agreed consideration, (iv) from a loss or liability in respect of an event, (v) the happening of which is uncertain, it will be considered to be in the nature of insurance. ... A cost-plus plan under which the administrator agrees to reimburse the proprietor, his or her spouse and members of his or her household for actual medical and hospital expenses and receives, as consideration, an amount equal to the amount reimbursed plus an administrative fee, does not qualify as a PHSP since it does not contain the necessary elements of insurance. ... The consideration given by the employee is considered to be the employee's covenants as found in the collective agreement or in the contract of service. ...

15 July 2008 External T.I. 2008-0275471E5 F- Société de personnes/Ajustement au PBR Unedited CRA Tags 53(1)e) 99(1) 40(1)a)(i) Principales Questions: D'ici la sanction du projet de loi modifiant le paragraphe 99(1), est-ce que l'ARC entend appliquer la loi de manière à ce que les revenus ou les pertes d'une société de personnes pour sa dernière année d'imposition avant sa dissolution soient pris en considération dans le calcul du PBR prévu à l'article 53? ... Vous désirez savoir si, d'ici la sanction du projet de loi modifiant le paragraphe 99(1), l'ARC entend appliquer la LIR de telle manière à ce que les revenus ou les pertes d'une société de personnes pour sa dernière année d'imposition avant sa dissolution soient pris en considération dans le calcul du prix de base rajusté (" PBR ") de la participation d'un associé en vertu de l'alinéa 53(1)e). ... L'utilisation à deux reprises de l'expression " immédiatement avant le moment donné " a pour but d'assurer que les revenus ou les pertes d'une société de personnes pour sa dernière année d'imposition avant la dissolution soient prises en considération dans le calcul du PBR des participations des associés aux termes de l'article 53. ...

Where the purchaser of a business acquires goodwill, as a recognizable asset, the consideration given for the goodwill will generally qualify as an eligible capital expenditure, as defined in subsection 14(5) of the Act. ... The consideration must include at least one share of the corporation. The transferor is permitted to dispose of the property to the transferee for an "agreed amount" which may be other than the fair market value of either such property or the consideration received for it, provided the agreed amount falls within certain limits. ...

TABLE RONDE SUR LES PRODUITS FINANCIERS APFF- CONGRÈS 2005 Question 7 Régime d'options d'achat d'actions En vertu de l'interprétation technique 2005-0112901E5 du 25 avril 2005, l'ARC mentionne que la juste valeur marchande (JVM) d'une action aux fins du calcul de l'avantage imposable en vertu de l'article 7 L.I.R. peut prendre en considération un escompte pour refléter la restriction quant au moment de la vente des actions. ... Michel Lambert 7 octobre 2005 2005-013299 957-8962 TABLE RONDE SUR LES PRODUITS FINANCIERS APFF- CONGRÈS Question 7 Stock Option Plan In technical interpretation 2005-0112901E5 dated April 25, 2005, CRA mentions that the fair market value (FMV) of a share for the purposes of calculating taxable benefit pursuant to section 7 of the ITA may take a discount into consideration to reflect restriction as to the time of selling the shares. ... CRA Response To establish the FMV of a corporate share acquired pursuant to a stock option plan, consideration must be given to the FMV of shares in an open market, and it must be established if there are grounds to consider a discount to take into account the fact that the shareholder cannot dispose of the share until a given date. ...