Search - consideration

Specifically, you ask if the policyholder dies, can an interest of the policyholder in a life insurance policy be transferred for no consideration on a rollover basis by his estate to the spouse, child or grandchild assuming that the transferee is the life insured. ...

Basically, an RESP is a contract between a subscriber and a promoter under which, in consideration of payments made by the subscriber, the promoter agrees to make educational assistance payments to a beneficiary. ...

Tang (613) 957-9229 July 31, 1987 Dear Sirs: This is in reply to your letter of March 10, 1987, wherein you submitted for our consideration your view on the tax consequences to XXXX in the manner described. ...

However, we have the following suggestions for your consideration to modify the report: 1. ...

Assuming that the facts of the case substantiate this change in business activities, the Department would normally take into consideration the manner in which the corporation is proposing to derive its revenue. ...

Your view with respect to this being an anomalous result would more appropriately be addressed to the Department of Finance for their consideration. ...

Generally, it is our view that the fair market rental value method should be used to determine the amount of the benefit, however, where the fair market value rental does not provide a reasonable return on the value or the cost of the property, the amount or value of the benefit being conferred on the shareholder is more indicative of the true value of the benefit when it is determined by a normal rate of return on the greater of the cost or the fair market value of the corporate asset plus the operating costs, less any consideration paid to the corporation by the shareholder. ...

It is not clear from the information you have provided whether this election would be advantageous to yourself, but we have included the bulletin for your consideration. ...

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... ...

Other consideration would be given to the possible application of sections 74.1, 74.2, 74.3, 74.4 and 74.5 of the Act which are a comprehensive set of rules designed to prevent the splitting of income through the transfer of property by an individual to a spouse or to a person under 18 years of age. ...