Search - consideration

An additional consideration is that Canadian income tax laws may be subject to the provisions of a tax convention or agreement between Canada and the foreign country in which the non-resident resides. ... For your further consideration, we are also providing you with comments relating to the income tax implications to the son should the apartment be disposed of at some future time following the transfer of the property from the non- resident. ...

The exclusion from the carved-out property rules, provided by paragraph 209(1)(c) of the Act, would not be met in this instance because the farmee's interest in the property was not acquired solely in consideration of his undertaking to incur Canadian exploration expense or Canadian development expense in respect of the property (i.e. the equipping costs taint the exclusion). ... It is the Department's position, as outlined in paragraph 11 of Interpretation Bulletin 125R3, that to the extent that an owner of a resource property (the “farmor”) transfers a part interest therein to another person (“the farmee”) in consideration of the farmee's agreement to incur exploration and development expenses on that property, the proceeds of disposition to the farmor and the acquisition cost to the farmee of the resource property will be viewed as being nil. ...

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. ...

A transfer of property to a registered charity is not a gift for the purposes of section 118.1 of the Income Tax Act (the "Act") if there is consideration of any kind being received in return.  In our view, the word "gift" has been interpreted as being a voluntary transfer of property without consideration and without conditions.  ...

The           24(1)       District Taxation Office subsequently disallowed those claims on the basis that the social assistance payments from the Ontario Ministry were "received" for the purposes of subparagraph 110(1)(f)(iii) by the Corporation rather than by the     19(1)      As paragraph 81(1)(h) of the Act has been recently enacted into law (Bill C-18),            19(1)              representative have requested consideration of whether the payments received by the   19(1)      in partnership from the Corporation are exempt under this provision. ... A further consideration is that paragraph 81(1)(h) refers to a "social assistance payment... made on the basis of a means, needs or income test to the extent that it was received directly or indirectly by the taxpayer for the benefit of another".  ...

Consequently, although 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, 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, 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, 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.  ...

As discussed in paragraph 3 of Interpretation Bulletin IT-339R2, a PHSP must be in the nature of insurance and must contain the following basic elements: i)      an undertaking of one person, ii)      to indemnify another person, iii) for an agreed consideration, iv)      from a loss or liability in respect of an event, v)      the happening of which is uncertain. ... With respect to your second question, provided the employees are not shareholders, the Department considers that, where a PHSP is self-insured (i.e., the consideration for the "insurance" is regarded as the employees' covenants in their contract of service with the employer), all employees (or all employees within a specific category) should be covered in one plan with the same coverage for each employee. ...

Nonetheless, we can comment that where a medical expense of the type under consideration is allowable, a deduction may be claimed for the purchase price of the equipment or, if applicable, for the cost of renting the equipment. ... Finally, we have forwarded a copy of your letter to our Current Amendments Division for their consideration in referring this matter to the Department of Finance, which, as you may know, is responsible for initiating amendments to the Income Tax Act and Regulations. ...