Search - consideration

Proposed subsection 248(31) provides that the amount of the advantage is generally the value of any property, service, compensation or other benefit received or obtained by the donor as partial consideration for, or in gratitude for, the gift. ...

If, however, this situation relates to a factual situation and a completed transaction, it should be submitted to the appropriate taxation services office for their consideration. ...

Your Question You have indicated that the Canada Customs and Revenue Agency (the "CCRA") has taken the view (paragraphs 38(b) and 39 of Interpretation Bulletin IT-474R) that where a taxpayer receives cash in lieu of fractional shares as a result of an amalgamation under subsection 87(1), the taxpayer will not be disqualified from the rollover treatment provided under subsection 87(4) and where the amount of cash received is less than $200, the taxpayer may either reduce the adjusted cost base, as defined in section 54, of the share consideration received or compute a gain or loss in respect of the appropriate fraction. ...

We recognize that the restrictions in paragraph 118.2(2)(n) may have been drafted without consideration of the unique circumstances faced by the taxpayer. ...

Where the shareholder or employee, as the case may be, and the corporation are dealing at arm's length and the shareholder or employee pays FMV consideration to the corporation to acquire the policy, it is our view that such a transfer would not be considered to have been made by way of gift, by operation of law only or by distribution from the corporation. ...

Accordingly, in the case of the NSULC, the consideration for the transfer to it of XXXXXXXXXX Class AX preferred shares of Investco will be XXXXXXXXXX Class A preference shares of the NSULC with a PUC of $XXXXXXXXXX per share or $XXXXXXXXXX in the case of the NSULC and an ACB of $XXXXXXXXXX per share or $XXXXXXXXXX in the case of the NSULC. ...

In particular your letter listed the following costs for our consideration: Sperm freezing- initial process, preparation and annual storage Embryo freezing- initial process, preparation and annual storage Sperm thawing Embryo thawing Transfer of frozen embryo Your letter also referred us to the web site for XXXXXXXXXX for additional information on the procedures mentioned above and acknowledged that you have reviewed Interpretation Bulletin IT-519R2. ...

Since your constituent's concern is a matter of tax policy, I am forwarding a copy of your correspondence to the Honourable John Manley, Minister of Finance, for his consideration. ...

The courts have described interest in general terms as "the return or consideration or compensation for the use or retention by one person of a sum of money, belonging to or owed to another". ...

A uranium deposit would constitute a "mineral resource" for purposes of the legislation under consideration. 2003-004350 XXXXXXXXXX A. ...