Search - consideration

Currently, the Fund pays XXXXXXXXXX to ensure that the Fund is not subject to income tax under Part I of the Act, after taking into consideration any capital gains refund available to it pursuant to subsection 132(1) of the Act. 7.If the fixed rate distributions exceed the Fund's net income and the non-taxable portion of any capital gains designated under subsection 104(21) of the Act in respect of unitholders of the Fund, the excess is a non-taxable return of capital. ... For the purpose of this ruling, the existing units will be reclassified as "Class A units" and the new class of units will be referred to as "Class B units". 10.Assuming that the unitholders approve the resolution to amend the declaration of trust for the Fund, the amendments to the declaration of trust will be implemented within 6 months of the date of this ruling (the "Effective Date"). 10.1Based on discussions with the dealers and brokers who represent the unitholders of the Fund, the Manager expects at least XXXXXXXXXX of the unitholders and as many as XXXXXXXXXX% of the unitholders of the Fund to convert their Class A units to Class B units beginning at the earliest opportunity after the Effective Date. 10.2The Manager further expects that within the one year period after the Effective Date some unitholders will convert their Class B units into Class A units. 11.The attributes of the Class A units will be substantially identical to the attributes of the units before the amendments to the declaration of trust, except that the Class A units will be convertible on any Business Day, at the option of the unitholder, into Class B units having an aggregate net asset value equal to the aggregate net asset value of the Class A units being converted, after taking into consideration the payment of any applicable redemption or exchange fees. ... As before, the Fund will distribute a sufficient amount of its net income each year to ensure that the Fund will not be subject to income tax under Part I of the Act, after taking into consideration any capital gains refund available to it pursuant to subsection 132(1) of the Act. 16.On the Effective Date and until the first quarterly distribution, the Class A units will have the same net asset value per unit as the Class B units. ...

A will transfer XXXXXXXXXX common shares to Holdco, and as sole consideration therefor Holdco will issue XXXXXXXXXX voting common shares. ... B will transfer XXXXXXXXXX common shares to Holdco, and as sole consideration therefor, Holdco will issue XXXXXXXXXX non-voting common shares. ... B as consideration for the transfers described in Paragraphs 9 and 10 above, not to be considered Capital Property to Mr. ...

Repo Agreements In a typical repo transaction, one party (the "seller") sells securities at fair market value to another party (the "purchaser") for cash consideration ("cash proceeds") and at the same time agrees to repurchase identical securities at a specified future time or on demand. ... It is a question of fact whether the requirements in clause 212(1)(b)(iii)(E) of the Act are satisfied. 4.Where the foreign branch (purchaser) enters into a reverse repo transaction that is a SLA with a foreign counterparty (seller) and the foreign counterparty receives money as consideration for the use of the securities, paragraph 260(8)(b) of the Act will apply to deem a lending fee to have been paid if the arrangement does not provide for a reasonable lending fee. ... Under that provision, the deemed lending fee is the difference between interest on the money held, calculated at a prescribed rate, and any amount which is paid or credited to the purchaser by the seller other than as a return of the consideration. 5.Regarding your question on whether the Department considers the bid-offer spread to be acceptable as a reasonable amount deemed to be a lending fee for the purpose of paragraph 260(8)(b) of the Act, we note that this matter falls within the purview of our Audit Directorate. ...

However, in relation to the circumstances under consideration, the comments in those paragraphs are only relevant if a shareholder severs all ownership ties with the corporation. ... As indicated above, the other consideration is whether the Debt was disposed "to a person with whom the taxpayer was dealing at arm's length" for the purposes of subparagraph 39(1)(c)(ii) of the Act. ... Nonetheless, as indicated to you in our telephone conversation, there is a further consideration, which involves IT-239R2. ...

XXXXXXXXXX The shares of XXXXXXXXXX are capital property to XXXXXXXXXX XXXXXXXXXX and they are all residents of Canada for purposes of the Act. 3.XXXXXXXXXX address is XXXXXXXXXX and its tax account number is XXXXXXXXXX The shareholders of XXXXXXXXXX their addresses and social insurance numbers ("SIN") are as follows: SHAREHOLDER ADDRESS SIN XXXXXXXXXX XXXXXXXXXX and its shareholders file their tax returns at the XXXXXXXXXX Tax Services Office and XXXXXXXXXX Taxation Centre. 4.XXXXXXXXXX will have RDTOH at the time of the commencement of the proposed transactions described herein. 5.The business of XXXXXXXXXX The real estate inventory of XXXXXXXXXX has been sold to arm's-length purchasers at fair market value in the ordinary course of business of XXXXXXXXXX in the Project will be sold to persons dealing at arm's length with XXXXXXXXXX for consideration that consists only of money or indebtedness that is not convertible into other property before the proposed transactions described herein. 6.The assets of XXXXXXXXXX have an estimated fair market value of $XXXXXXXXXX made up of cash, term deposit and interest income receivable. ... As sole consideration for such transfer, Holdco XXXXXXXXXX will issue to each of XXXXXXXXXX common shares and a promissory note in the amount of $XXXXXXXXXX 16.The XXXXXXXXXX will incorporate a corporation under the XXXXXXXXXX ("Holdco XXXXXXXXXX"). ... As sole consideration for such transfer, Holdco XXXXXXXXXX will issue to each of XXXXXXXXXX common shares and a promissory note in the amount of $XXXXXXXXXX 18.In connection with each transfer of shares described in paragraphs 15 and 17 above, the transferor and transferee will jointly elect in prescribed form within the time limit referred to in subsection 85(6), to have the provisions of subsection 85(1) apply to the transfer. ...

No consideration is given to the number of copies of the works which are available, or to the actual circulation rate of the works. ... No consideration is given to works which may be found in other libraries which did not form part of the sample. ... Moore Prize and the Petro-Canada Award for Media Arts were also selected from Council grant recipients; the Sir Ernest MacMillan Memorial Prize in Choral Conducting and the Jean-Marie Beaudet Award recipients were selected from the competitors for Arts Awards grants in choral and orchestral conducting; and, the Jules Leger Prize (which is administered on behalf of the Council by the Canada Music Council) is awarded to individuals who apply to the Canada Music Council for consideration. ...

The third party typically pays the franchise holder to surrender his existing rights and A Co. issues a new franchise to the third party for no further consideration. ... The consideration given by Newco for the right or option is shares of Newco. ... Other Issues The Department may consider that paragraph 110.6(7)(b) of the Act is applicable if fair market value consideration is not received from Newco for the transfer of the option or exclusive right by C. ...

The private corporation, as consideration, will issue new shares to the estate having a paid-up capital and fair market value equal to the purchase price. ... For example, if the shares owned by the estate are repurchased for consideration consisting of retractable preferred shares and the retraction of such shares by the estate would have an adverse impact on the operations of the corporation, then the estate could be considered to have some influence which could result in de facto control of the corporation. The determination of whether the estate has any such influence over the corporation can only be made following a consideration of all of the facts related to a particular situation. ...

We are of the view that section 68 of the Act applies to reduce the proceeds of disposition for the shares of Oldco to the amount corresponding to the FMV established by the Valuation Unit that can reasonably be regarded as being the consideration for the disposition of the shares. ... Where an individual receives only non-share consideration, the excess of the consideration received over the greater of the paid-up capital or the adjusted cost base of the shares sold is deemed to be a dividend pursuant to subsection 84.1(1)(b) of the Act. ...

An annuity or other periodical payment made, esp. by a government, a company, or an employer of labour, in consideration of past services." Accordingly, a plan will, in general, be considered to be a superannuation or pension fund where contributions have been made to the plan by or on behalf of an employer or former employer of an employee in consideration for services rendered by the employee and the contributions are used to provide an annuity or other periodical payment on or after the employee's retirement in consideration for his or her employment services, and, in some cases, where amounts have been contributed under the plan by a government. ...