Search - consideration

I understand that you have already written to the Honourable Chrystia Freeland, Minister of Finance, about the taxation of your commuting allowance; I have confidence that her office will give all due consideration to your correspondence. ...

You have referred to the situation of an individual who has a portfolio of several different stocks who wishes to attend these meetings for reasons relating to the retention or possible disposal of the shares, dividend payments or capital gains considerations. ...

A determination of the reasonableness of the amount of remuneration paid to any particular employee requires consideration of the duties performed by the individual, as well as the time spent in carrying out those duties.  ...

This matter has been brought to the attention of the Department of Finance for consideration of an appropriate technical amendment. ...

Comments As stated in the reply to question 13 at the 1980 Revenue Canada Round Table, the Department is concerned with the fair market value of the shares received as consideration for the shares transferred to the corporation pursuant to subsection 85(1) of the Income Tax Act (Canada)  (the "Act").  ...

You provided the following scenario for our consideration. Taxation Year for Deduction By Contributor Date of Depositto SpousalRRSP Amount 1986 February 5, 1987 $1,000 1987 January 1, 1988 $1,000 1988 March 1, 1989 $   500 The entire amount is withdrawn from the spousal RRSP on January 1, 1991. ...

The same consideration applies with respect to GIC issued by a trust company. ...

Of all the provinces, it appears that only Manitoba has taken this into consideration.  ...

It would appear from our reading of the translation of the German decision that the German court considered that the vendor/licensor, not the purchaser/licensee, is the person upon whom the German VAT is imposed and who is liable therefore and that accordingly the VAT is included in the vendor's/licensor's income for income tax purposes as described in the first paragraph on page 2 of our Memorandum to you dated May 7, 1991, namely: "If, on the other hand, the VAT is a tax imposed on the vendor/licensor as the person primarily liable therefore (as opposed to merely being liable in its capacity as a collecting agent with an absolute obligation to collect), as appears to be indicated in the letter to you from the German competent authority dated August 17, 1990, we would be inclined to conclude that the entire amount payable to or for the account of the vendor/licensor or for which the vendor/licensor obtained credit against its VAT liability by virtue of action taken by the purchaser/licensee would be "consideration for the use of, or the right to use, any copyright, (etc.)... ...

However, we offer the following comments for your consideration. 1.      ...