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Results 141 - 150 of 208 for consideration

Amanda S.A. Doucette, Britney Wangler, "Normal Borrowing by CCPC Owners Can Create an Income Inclusion", Canadian Tax Focus, Vol. 7, No. 1, February 2017, p. 1 -- summary under Specified Right

In order for the bank not to have a specified right, the key consideration is that the secured property can be used only to repay the shareholder debt. ...

Elie Roth, Tim Youdan, Chris Anderson, Kim Brown, "Taxation of Trusts Resident in Canada", Chapter 3 of Canadian Taxation of Trusts, (Canadian Tax Foundation), 2016. -- summary under Subsection 248(8)

When a person executing a disclaimer receives consideration, a question can arise whether the disclaimer is valid... ...

Gregory M. Johnson, Wesley R. Novotny, "An Update on Flow-through Shares in the Energy Sector", 2016 Conference Report (Canadian Tax Foundation),12:1-39 -- summary under Paragraph 6202.1(1.1)(c)

[P]aragraphs 66(12.66)(a.1) and (c) require that the subscription agreement and the consideration be received in the same calendar year.... ...

Gregory M. Johnson, Wesley R. Novotny, "An Update on Flow-through Shares in the Energy Sector", 2016 Conference Report (Canadian Tax Foundation),12:1-39 -- summary under Subparagraph 12(1)(x)(iv)

Consideration should be given to whether the partnership or the partner should make the election. ...

Allan Gelkopf, Robert Kreklewich, Zvi Halpern-Shavim, "Finance Canada Seeks Comments on New Tax Proposals Regarding Investment Limited Partnership Rules", Canadian Current Tax, Vol. 28, No.1, October 2017 p. 4 -- summary under Subsection 272.1(8)

The rules simply deem a certain amount of consideration, based on an arm's length fair market value test, to have been paid to the general partner and the partner is required to remit GST/HST on that amount, without regard to the partnership distributions that are paid. ...

Joint Committee, "Subsection 55(2) Amendments – Follow-Up to Our Meeting with Canada Revenue Agency", 19 January 2018 Joint Committee Submission to Finance respecting s. 2015 s. 55(2) Amendments including appended 20 April 2017 letter to Randy Hewlett on such Amendments -- summary under Subsection 55(2)

Request for Finance to consider The letter to Finance noted that CRA was able to deal only with some of the issues, which were subsequently discussed at the 2017 Annual CTF Roundtable, and asked for Finance’s consideration of these issues. ...

Tina Korovilas, Drew Morier, "Non-Corporate Vehicles in the Foreign Affiliate Context", 2018 Conference Report (Canadian Tax Foundation), 20:1 – 114 -- summary under Ownership

The Queen, 2012 TCC 57 for the judicial consideration of the meaning of “beneficial owner” in the context of tax treaties.] ...

Martin Lee, Thanusan Raveendran, "Affiliation Election for CEWS: Private Corporation Applications", COVID-19 and Canadian Tax for the Owner-Manager/Canadian Tax Focus (Canadian Tax Foundation), July 2020, p. 3 -- summary under Paragraph 125.7(4)(b)

Must consider qualifying revenue of all affiliated eligible entities (p. 4) [T]he affiliation election must take into consideration all affiliated eligible entities; an applicant cannot pick and choose which affiliated parties to consolidate with. …. ...

Stan Shadrin, Alex Ghani, Josh Harnett, "Corporate Partnership May Avoid the Paragraph 125(5.1)(b) Grind", Tax for the Owner-Manager, Vol. 20, No. 4, October 2020, p.4 -- summary under Subsection 125(5.1)

Potential for spousal Holdcos to be associated under s. 256(2.1) (p.5) Consideration should be given to … subsection 256(2.1) …. ...

Joint Committee, "Excessive Interest and Financing Expenses Limitation Proposals", 5 May 2022 Submission of the Joint Committee -- summary under Subparagraph (c)(iv)

Also, consideration should be given to adding a look-through test, for example, if 11% of an entity’s IFE is paid to a partnership with an 11% non-resident partner, it would be disqualified even though, on a look-through basis, only 1.21% of the IFE was ultimately allocable to that non-resident. ...

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