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Otherwise, the additional consideration (i.e., the amount that is over and above the FMV) that was paid to the corporation may be considered to be assistance for the purposes of calculating the CPTC or the PSTC, or an acquisition of interest in the corporation or the corporation’s business or property, depending on the facts and circumstances of the situation. ... In the case of film and video productions, crowdfunding allows producers to finance, in whole or in part, their projects or promotional activities usually in return for non-monetary considerations offered to contributors (i.e., the donation model). ...

(Black's Law Dictionary) settlor means one who furnishes the consideration for the creation of a trust, though in form the trust is created by another. ... Transfer of Title to and from the Trustee Sections 268 and 269 of the Act provide that where a person settles property in an inter-vivos trust and where the trustee distributes property of the trust to the beneficiaries, the settling or distribution of the property is deemed to be a supply for consideration equal to the amount determined under the Income Tax Act. ...

. ¶1.9 (formerly included in ¶5 of IT-270R3) now includes a reference to documentary or stamp taxes in the examples of items not considered to be income or profits taxes in consideration of the CRA’s position on the general nature of these taxes. ¶1.10 (formerly included in ¶5 of IT-270R3) has been revised to change business income to net business income in the first sentence for greater clarity. ¶1.16 (formerly included in ¶7 of IT-270R3) now includes an example describing a taxpayer with different taxing and business countries. ¶1.25 (formerly included in ¶8 of IT-270R3) has been reworded to remove ambiguity as to whether foreign was meant to describe the other person or partnership and to better reflect paragraph (e) of the definition of non-business-income tax in subsection 126(7). ¶1.26 (formerly included in ¶8 of IT-270R3) now includes a reference to the amendments to the overseas employment tax credit contained in the Jobs and Growth Act, 2012; edited to remove redundancy. ¶1.29- 1.31 are new additions which replace and expand on the parenthetical comment in ¶8 of IT-270R3, which read: (subject to subsections 126(4.1) and (4.2), which concern the no economic profit and short-term security acquisitions rules, respectively) ¶1.32- 1.35 (formerly included in ¶11 of IT-270R3) has been revised to omit the last sentence of former ¶11 and to add a discussion on what is meant by paid by the taxpayer for the year. ¶1.39 replaces and expands on the partnership information contained within parenthesis at ¶1- 2 of IT-270R3. ¶1.41 (formerly included in ¶15 of IT-270R3) has been revised to de-emphasize the word spouse and place greater emphasis on the filing of a valid, foreign, communal return. ¶1.42 (formerly included in ¶16 of IT-270R3) has been expanded to reflect amendments to section 261 and the CRA’s position regarding consistency in exchange rate methodologies. ¶1.46 (formerly included in ¶20 of IT-270R3) has been revised to clarify the situation of income arising from property which pertains to or is incidental to a foreign business. ¶1.49 (formerly included in ¶21 of IT-270R3) now references the Canada-UK Income Tax Convention. ¶1.51 (formerly included in ¶22 of IT-270R3) now contains a sentence to address subsection 91(5). ¶1.52 is a new paragraph added to point out that where a treaty is applicable; the treaty may have its own income sourcing rules which supersede those of the Act, but only for the purposes of eliminating double taxation in accordance with the treaty. ¶1.53 (formerly included in ¶23 of IT-270R3) now includes the phrase or profit generating activities for greater clarity, as well as a bullet referencing transportation or shipping businesses. ¶1.54 is a new paragraph added to reflect the jurisprudence on additional factors and the weighting of various factors when determining the location of the source of the business income. ¶1.57 (formerly included in ¶25 of IT-270R3) has been revised to change place to physical place to remove ambiguity. ¶1.58 (formerly included in ¶26 of IT-270R3) contains new sentences that reflect additional factors concerning the situs of income and their weight, as judicially addressed. ¶1.62 (formerly included in ¶3 of IT-395R2) has been revised to add and title was transferred to the second sentence and to add the third sentence for greater clarity. ¶1.63 (formerly included in ¶3 of IT-395R2) has been revised to add the phrase under the Act to remove ambiguity and to differentiate between foreign deemed dispositions and deemed dispositions under domestic law. ¶1.65 (formerly included in ¶4 of IT-395R2) now includes examples and a discussion of the relative weighting of various factors for consideration. ¶1.69 is a new paragraph added to address TFSAs and RRSPs. ¶1.70- 1.72 (formerly included in ¶37 of IT-270R3) has been revised to reflect legislative changes effective for the 2005 and later tax years, to make reference to the additional definitions involved, and to reference Guide 5000-G, General Income Tax and Benefit Guide. ¶1.73 (formerly included in ¶40 of IT-270R3) has been revised to change the treaty in the example to the Canada-India Treaty. ¶1.76 (formerly included in ¶2 of IT-270R3) has been revised to match the marginal note of subsection 120(1). ¶1.79 (formerly included in ¶3 of IT-270R3) has been expanded to better explain the operation of section 114 and subparagraphs 126(1)(b)(ii) and 126(2.1)(a)(ii). ¶1.80 (formerly included in ¶30 of IT-270R3) now includes the phrase not under the laws of the foreign jurisdiction in the first paragraph for greater clarity. ...

Other promoters stated their requests were very complex and required additional tasks, including: driving applicants to medical appointments, pre-screening DTC applications to ensure that only valid DTC requests are submitted to the CRA, following up with medical practitioners to ensure that the right information is given on the DTC certificate, operating their own call centres to support their clients, advertisement and office overhead, geographic considerations for overhead expenses, postage for shipping documents across Canada to obtain doctor reports and signatures on the DTC certificate, and adjusting multiple tax returns for anyone who could have supported the person with a disability. ... The CRA will continue its efforts to constantly improve the service it offers to Canadians by addressing the items that can be acted on in the short term and give due consideration to other items as part of our long term strategy. ...

We will take into consideration any personal information that the debtor presents that may affect this ability. ... If you transfer property to a spouse or a person who has since become your spouse, a person under 18 years of age, or a person with whom you were not dealing at arm’s length, that person becomes liable for the lesser of the amount you owe, or the excess of the fair market value of the property over the consideration given for the property. ...

However, in the case of a Canadian partnership the elective provisions of subsection 97(2) permit it to be transferred at an "agreed amount" which cannot exceed the fair market value of the work in progress and cannot be less than the consideration received by the transferor, but may be any amount between fair market value and nil (inclusive) when no consideration is received by the transferor. ...

" Where a stated price net of rebates is used, a calculation must be made to determine the value of the consideration payable for the housing. The value of the consideration must be calculated before the tax payable can be determined. ...

" Where a stated price net of rebates is used, a calculation must be made to determine the value of the consideration payable for the housing. The value of the consideration must be calculated before the tax payable can be determined. ...

When accessories are sold together with zero-rated farm equipment for a single consideration, but are not attached to or installed on the equipment, the supply of the accessories is deemed to form part of the supply of the equipment, provided the supply of the accessories is incidental to the supply of the equipment. ... The invoice is for a single consideration of $45,150. The farmer will attach the tool box to the tractor. ...

Please refer to the current issue of Information Circular 71-17, Requests for Competent Authority Consideration Under Mutual Agreement Procedures in Income Tax Conventions, with respect to requests for competent authority consideration. ...