Search - consideration

It is your view that when, in the circumstances described above, the employee elects to receive cash, the amount so received represents consideration for the disposition of his rights to acquire shares under the stock option plan. You submit that a benefit equal to the value of the consideration so received would be included in the employee's income for the year by virtue of paragraph 7(1)(b) of the Act and that the employee would be entitled to deduct one-half of this benefit pursuant to paragraph 110(1)(d) of the Act. ...

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, those CPP contributions paid in the year prior to the leave period must be taken into consideration by the trustee. ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year. ...

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, those CPP contributions paid in the year prior to the leave period must be taken into consideration by the trustee. ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year. ...

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, those CPP contributions paid in the year prior to the leave period must be taken into consideration by the trustee. ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year. ...

This assumes, of course, that the information submitted by you to Accounting and Collections reflects the true state of affairs between XXXX and an Independent Contractor, and that the comments of Accounting and Collections in their letter of October 23, 1985, regarding the other other rules and regulations of XXXX are taken into consideration. ... In this regard, such market rate would be established taking into consideration the normal lending practices of financial institutions, but excluding a rate calculated in a "mortgage buy-down" transaction that may be offered by a third party lender. ...

Where a shareholder of a corporation guarantees for no consideration the payment of amounts to be paid by the corporation, this act alone would normally not represent a payment to a third party to fund the payments. It is our view that it would represent such a payment, however, if the shareholder received consideration for the guarantee. ...

The preferred shares were issued as consideration for assets transferred to Opco pursuant to a joint election filed under subsection 85(1) of the Act. The preferred shares are entitled to a non-cumulative dividend, rank in priority to the common shares on a winding-up of Opco, and are redeemable at a redemption price which reflects the fair market value of the assets in consideration for which they were issued. ...

In the case of point number 3, the first sentence of clause number 2 of the Agreement indicates that the purchase price for the shares/debt is to be calculated in accordance with the price at which the "Property" is sold; however, while the first sentence of clause number 3 of the Agreement appears to require the "Purchaser" to sell the "Property" to a nominee of the "Vendor" for fair market value consideration this point is confused by the last sentence of clause 3 of the Agreement which appears to imply that the "Purchaser" could also sell the "Property" to third parties without any stated requirements that the sale be for fair market value consideration. ...

As well, different considerations might apply if takeovers were a common occurence such that the parent corporation might be said to be in the business of acquiring corporations. ... General The responses set out in this letter are purely of a general nature and do not take into account the numerous additional considerations that might arise in the context of specific factual situations. ...

If the employees subsequently exercise their option, then any proceeds received by Corporation A as consideration for the granting of the option would be added to the proceeds received as consideration for the sale of the shares of Corporation B by virtue of subsection 49(3) of the Act. ...