Search - consideration

(d) The agreement must represent a bona fide business arrangement and not a device to pass the decedent's shares to his/her heirs for less than an adequate and full consideration. 29. ... (b) The stipulated price or formula price in the agreement provides full and adequate consideration, and represents the fair market value of shares determined without reference to the agreement at the time it is executed. ...

Each method includes the same consideration and review of all relevant information, however it is the timing of the identification of the taxpayer that differs in these two methods. 23. ... Based on the preliminary information provided by the taxpayer as described in paragraph 44, the VDP officer may confirm that there is nothing set out in the information provided that may immediately disqualify the taxpayer from further consideration under the VDP. ...

., there was a direct link established between the funds received and the activities), but was consideration for a taxable supply. ... An audit determined that the amount of money that the pulp and paper mill operator received from the federal government was not a grant (i.e., there was a direct link established between the funds received and the activities), but was consideration for a taxable supply. ...

Under this provision, all the consideration receivable upon conversion or exchange has to be a share or warrant as described above. An exception is made for consideration received in lieu of a fraction of a share. ...

After submitting a Request, you must inform Competent Authority of any material change in the information or documentation previously submitted as part of, or in connection with, the Request, as well as new information or documentation relevant to the issues under consideration. If you do not provide complete and accurate information or make a misrepresentation then the Competent Authority may suspend or terminate its consideration of your Request. 13. ...

At the close of the most recent fiscal year, 35 applications were still under consideration for acceptance to the program (that is, instances where a pre-file meeting has occurred between the CRA and a taxpayer, but a taxpayer's acceptance to the program had yet to be granted by the close of the fiscal year). This figure alone, without any consideration of pre-file meetings that may take place in the coming year suggests that there could be as many as 35 new cases accepted into the program in fiscal year 2013-14. ...

It should also be noted that all subsection 247(2) transfer pricing adjustments under consideration that exceed the threshold for penalty consideration in subsection 247(3) will be referred to the Transfer Pricing Review Committee for review. ...

Similarly, an automobile lease payment although partially consisting of a financing component is not exempt as consideration for a supply of a financial instrument. ... It is an agreement by which one party, for a consideration, promises to pay money or its equivalent, or to perform an act valuable to the other party upon destruction, loss or injury of something in which the other party has an insurable interest. ...

Some of the information included in the financial statements, such as accruals and the allowance for doubtful accounts, is based on management's best estimates and judgment, with due consideration to materiality. ... More specifically, project alignment with the priorities outlined in the Corporate Risk Profile is one of the considerations used to inform the priority ranking of initiatives. ...

The project leads for the pilot sites worked closely with senior management to integrate SD considerations in their planning processes, and included SD commitments in the performance contracts of senior managers. ... Promoted the guidance document released by the SD Division for the management of construction and demolition waste to all RPSD staff, as well as sensitized them on how to incorporate SD considerations into major renovation projects. ...