Search - consideration

In such cases, the services are rendered primarily for the benefit of the employer and the payments represent consideration for the services, usually based on the time spent providing the services or the value or volume of these services. ... Fellowship awards are made on the basis of the demonstrated merit and potential of the applicant, taking into consideration the applicant's academic record, research ability, and references.? ... While the Document is by no means a substitute for the actual terms and conditions of the arrangement with the Payee, the general guidelines therein when taken into consideration with the specific information noted above, indicate the existence of an employee-employer relationship. ...

Under subsection 44.1(6), where an individual receives ESBC shares (the "new shares") as the sole consideration for the disposition of shares issued by another corporation that were ESBC shares ("exchanged shares"), the individual is deemed to own the new shares throughout the period that he or she owned the exchanged shares provided that certain conditions are met. ... Similarly, under subsection 44.1(7) where an individual disposes of common shares of a corporation ("exchanged shares") and receives as consideration only common shares of another corporation ("new shares"), the new shares are deemed to be ESBC shares and shares of an active business corporation that were owned by the individual throughout the period that the exchanged shares were owned by the individual provided again that certain conditions are met. ... With respect to your comments concerning the possible revision of IT-259R3 in order to deal with new section 44.1, please note that there is no plan to make such a revision at this time, however we have forwarded your suggestion to our Technical Publications and Projects Section for their consideration. ...

We acknowledge, however, that although the wording of section 86.1 is slightly different in this respect from other rollover provisions in the Act that require that only share consideration be received by the taxpayer (for example, subsections 51(1), 85.1(1) and 87(4) of the Act), the position we take on this matter may have an impact on our interpretation of such provisions. ... There may be U.S. considerations behind this particular ordering; if so, we would want to examine these considerations in the context of a particular proposed foreign spin-off. ...

An inter vivos personal trust is a trust under which no beneficial interest was acquired for consideration payable directly or indirectly to the trust or to any person who made a contribution to the trust by way of transfer, assignment or any other disposition of property. For this purpose, the settlor of a trust who also has an interest in that trust is not considered to have acquired an interest in the trust for consideration solely because of his or her transfer of property to the trust. ... Whether the administrative practice would be expanded to cover a situation in which the shares of a single purpose corporation are transferred inter vivos to an alter ego trust can only be determined after taking into consideration all of the relevant facts and in the context of an advance income tax ruling. ...

Unlimited number of XXXXXXXXXX preferred shares with a non-cumulative dividend not exceeding XXXXXXXXXX% per annum, redeemable and retractable for an amount equal to the consideration for which such shares were issued (i.e., $XXXXXXXXXX per share).? Unlimited number of XXXXXXXXXX preferred shares with a non-cumulative dividend not exceeding XXXXXXXXXX% per annum redeemable and retractable for an amount equal to the consideration for which such shares were issued (i.e., $XXXXXXXXXX per share).? Unlimited number of voting XXXXXXXXXX preferred shares (one vote per share), retractable for an amount equal to the consideration for which such shares were issued (i.e., $XXXXXXXXXX per share), not entitled to any dividends.? ...

., (a) an undertaking by one person (the proprietor), (b) to indemnify another person(the employee), (c) for an agreed consideration, (d) from a loss or liability in respect of an event, (e) the happening of which is uncertain. ... In this regard, it must contain the following basic elements: (a) an undertaking by one person, (b) to indemnify another person, (c) for an agreed consideration, (d) from a loss or liability in respect of an event, (e) the happening of which is uncertain. As stated in interpretation letter #9904155, dated April 28, 1999, it is our view that a plan which consists of a contract between a proprietor and an administrator, under which the administrator agrees to reimburse the proprietor, his or her spouse and members of his or her household for actual medical and hospital expenses and receives, as consideration, an amount equal to the amount reimbursed plus an administrative fee, does not qualify as a PHSP since it does not contain the necessary elements of insurance. ...

Funded by share capital subscribed for by ACO, ECO purchased all outstanding shares of Old DCO for aggregate consideration of approximately $XXXXXXXXXX. ... In addition, these shares: f) will not be shares in respect of which any person or partnership will be obligated to effect an undertaking described in subsection 112(2.2); g) will not be part of a dividend rental arrangement as defined in subsection 248(1); h) will not be shares in respect of which: i) any person or partnership will be obligated to effect an undertaking described in paragraph 112(2.4)(a); or ii) the consideration for which the shares will be issued will not be or included any obligation described in subparagraph 112(2.4)(b)(i) or a right described in subparagraph 112(2.4)(b)(ii). 9. CCO will immediately advance the proceeds from the issuance of the preferred shares to DCO in consideration for an unsecured promissory note bearing interest at XXXXXXXXXX%. ...

H proposes to sell his interest in the Partnership, at a price equal to its fair market value, to the Company and in consideration therefor, the Company will issue to H a promissory note equal to such fair market value. ... On the day following the transaction described in 10 above, W proposes to sell her interest in the Partnership, at a price equal to its fair market value, to the Company and in consideration therefor, the Company will issue to W a promissory note equal to such fair market value. ... While H and W will own the Farmland, their intent is to rent it to other farmers for cash consideration or to sell it. 16. ...

In summary, the situation under consideration is as follows: XXXXXXXXXX In your opinion, as a material portion of the judgrnent pertains to the redemption of capital, i.e. ... In the Income Tax Technical News # 3, the Agency's view on a promissory note issued as consideration for the redemption or purchase for cancellation of a corporation's capital stock is as follows: "It is the Department's view that the interest payable on a promissory note issued as consideration for the redemption or purchase for cancellation of a corporation's capital stock is not deductible under paragraph 20(1)(c). ...

In consideration for the Transferred Opco Shares, Newco issues to Mr. ... (c)     Opco then sells to Newco the Non-Qualifying Assets at their fair market value of $200,000, and receives as consideration therefore redeemable preference shares of Newco with an aggregate redemption amount and fair market value of $200,000 and having nominal paid-up capital. ... has not identified a potential purchaser of the Opco Shares and he has no intention of selling the Opco Shares ("Situation 1"); (b)     at the time or the Reorganization, the sale of the Opco Shares is not under consideration or negotiation, although there are several potential purchasers in the marketplace and an offer could be received or negotiations commenced soon after the Reorganization ("Situation 2"); or (c)     at the time of the Reorganization Mr. ...