Search - consideration

CRA apparently considers that such payments (viewed by it as “franchise fees”) likely are consideration for the supply by the franchisor of “intangible personal property,” namely, “the right to operate a franchise which includes the right to use the name of the franchisor as an advertising tool and any systems made available by the franchisor to facilitate the operation of the franchise.” ...

Headquarters will generally, in turn, refer the matter to the GAAR Committee for consideration. ...

Court of Appeal) found that the Plan of Arrangement for the Exxon acquisition of InterOil should not be approved given that Exxon and InterOil did not in its view counter the testimony of Peter Dey that the process undertaken by the InterOil board did not meet current governance best practices and of a oil and gas expert that the consideration was inadequate. ...

Summary of Alison Spiers, "ECP Planning: Some Practical Considerations", Canadian Tax Focus, Vol. 6, No. 4, November 2016, p 1 under s. 248(1) – disposition. ...

V, s. 15.1, the first buyer must have documentation satisfactory to CRA that the CTC has been supplied to a registrant and all or part of the consideration is property of the same class or kind delivered to the first buyer outside Canada. ...

For example, a university whose predominant purpose is education and research would generally not acquire its main campus over 40% for the purpose of making taxable supplies for consideration. ...

6 January 2017- 12:53am Kirkland Lake was merged on a triangular amalgamation with a Newco subsidiary of Newmarket Gold Email this Content Kirkland Lake amalgamated with a wholly-owned subsidiary of Newmarket Gold on a triangular amalgamation occurring as part of a CBCA Plan of Arrangement, so that the shares of the Kirkland shareholders were cancelled in consideration for the receipt by them of shares of Newmarket (to be renamed Kirkland Lake Gold Ltd.) ...

CRA has published its view (confirming 8 January 2016 Interpretation 150125) that such fees not only are not for exempt health services, but constitute consideration for supplies by the doctor of intangible personal property. ...

However, whether the rule applied would depend on whether the linkage test was met, which would require consideration of relevant factors such as the timing and quantum of the dividend payments. ...

16 October 2017- 12:22am The proposed ETA s. 272.1(8) is not a general partner distribution recharacterization rule Email this Content The draft ETA s. 272.1(8) rule merely deems fair market value consideration to have been paid to the general partner of an investment limited partnership for its management and administration services, without regard to the partnership distributions (such as on a “carry”) that in fact are paid. ...