Search - consideration

Consideration received includes preferred shares of Newco with a PUC of $3.5 M, redeemable at $3,500,500, ACB $500. ...

As stated in paragraph 10 of Interpretation Bulletin IT-502, the Department will give consideration to the application of subsection. 56(2) (indirect payments) where payments are made to persons other than the employee or former employee while alive. ...

The determination of whether a money-lending business is being carried on is a question of fact which requires a full knowledge of the relevant circumstances of the particular case under consideration. ...

The MLP is established on the basis of a new car and takes into consideration the cost of the optional features added to the car assuming they are owned by the leasing agency. ...

If you have a factual situation in mind, you may wish to provide full details to the local district taxation office for their consideration. ...

Therefore income deferred in respect of services rendered after June 26, 1986 will be required to be included in the participants' income for the year of deferral. 2) There is no provision in the Income Tax Act (the "Act") to grant special tax consideration to deferred earnings that are required to be included in 1986 or 1987 taxable income regardless of the date of Royal Assent. 3) There are no provisions in the Act to permit the transfer of funds in the Plan to a registered retirement savings plan. ...

Income Tax Convention (1980) (the "Convention") defines the term "royalties (for purposes of that article) to mean"...Payments of any kind received as consideration for the use of, or the right to use, any copyright of literary... work... or for the use of, or the right to use, tangible personal property or for information concerning industrial, commercial or scientific experience... ...

The Court was of the view that the payments were made primarily for reasons unrelated to the employment relationship, namely, public and labor relations considerations. ...

It should be noted that this attribution rule is not applicable in respect of property transferred to the trust for fair market consideration. ...

The amount of reduction available would be based on the facts and circumstances surrounding each case (with consideration being given to the frequency and degree of loss of privacy and quiet enjoyment, for example). ...