Search - consideration

In your enquiry you have specifically noted that, in your view, the additional 8% Ontario sales tax should not be considered as part of the insurance premium since it is clearly not paid as consideration for a contract of insurance. ...

Our Comments: Whether or not the requirements embodied in the above quoted words are satisfied in a particular situation is a question of fact which can only be resolved after consideration of all of the relevant facts of that situation. ...

The material included with your correspondence indicates that each $XXXXXXXXXX investment unit which was offered and issued by XXXXXXXXXX entitled investors to the following: XXXXXXXXXX XXXXXXXXXX In our view, the entitlements in 2 to 5 above cause the issued flow- through shares to be prescribed shares pursuant to subparagraph 6202.1(1)(b)(iii) and (iv) of the Income Tax Regulations (the "Regulations") with respect to the XXXXXXXXXX Regulation 6202.1(1)(c)(ii) would also be applicable with respect to the income and dividend distributions related to the XXXXXXXXXX In addition, Regulation 6202.1(1)(d)(iii) is applicable with respect to the cash and benefits related to the entitlements that clearly represent a repayment or return of consideration for which the flow- through shares were issued. ...

As a comment it would seem that consideration should be given to the possible application of the general anti-avoidance provision should the arrangement be structured to produce an inappropriate income tax result. ...

Unfortunately, the taxpayer's argument that "a truck driver is a truck driver" is given secondary consideration in these circumstances. ...

If you would like assistance in determining the appropriate tax reporting in the specific case at hand, you should submit a copy of the original grievance and the court order or settlement agreement to your local district taxation office for their consideration and reply. ...

Volunteer fire fighter: A person who voluntarily acts as a fire fighter for a nominal consideration or honorarium. ...

The individual ceases to be a resident of Canada at a particular time, and at that time, the stock option, which was issued to him for no consideration, has a fair market value (FMV) in excess of nil. ...

La question a été soumise au ministère des Finances pour leur considération. ...

As mentioned to you at our meeting, the Department is in the process of writing draft guidelines, taking into consideration the representations made to us during our discussions with various Indian organizations and other interested parties. ...