Search - 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.  ...

Our Comments Generally, the reasonableness of a reserve will be acceptable if in the calculation of the reserve, consideration is given to any mortgages assumed by a buyer in situations where the vendor has previously given a mortgage to a third party either at the time of acquisition of the land or to finance the cost of improvements to the land including construction of a building on the land.  ...

You have submitted for our consideration the following hypothetical  situation: Hypothetical Situation:-      Limited Partnership A ("Partnership") is a Limited Partnership  which carries on the business (in Canada) of mining, processing and sales of the processed product.-      Partnership is owned as to 60% by a German resident individual, Mr. ...

Only loans which are unconditionally repayable would be excluded. 24(1) 24(1) 24(1)      IT-239R2 discusses the deductibility of capital losses from guaranteeing loans for inadequate consideration and from loaning funds at less than a reasonable rate of interest in non-arm's length circumstances.  ...

., 90 DTC 6150 (Federal Court- Trial Division), Jerome, A.C.J. states, at page 6151:      "But notwithstanding the fact that those people (in previous cases) were professional traders, there can always be one different purchase which requires special consideration.  ...

The Department in fact allocated $15,000 of the amount received as consideration in respect of a government right. ...

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... ...

30 May 1991 External T.I. 9013245 F- Interpretation of the Definition of "Taxable Preferred Share" Unedited CRA Tags 248(1) taxable preferred share 5-901324 Dear Sirs: Re:  Interpretation of the Definition of "Taxable Preferred Share" in Subsection 248(1) of the Income Tax Act (the "Act") This is in reply to your letter dated June 13, 1990, whereby you requested our opinion concerning our interpretation of paragraph (b) of the definition of "taxable preferred share" in subsection 248(1) of the Act, in a situation which you described as follows: 24(1) You requested our opinion as to whether a 24(1) could be considered to be a "taxable preferred share" by virtue of clauses (b)(i)(A) or (C) of the definition of that expression in subsection 248(1), and whether the phrase "it may reasonably be considered having regard to all the circumstances" in that definition provides any latitude in the applicability of the dividend entitlement clauses under consideration. ...

You point out that the issue of the shares would not arise as a result of a transfer of assets, and that in the hypothetical situation you have in mind, the shares would not only be issued for nominal consideration, but would also be redeemable for a nominal value. ...

It should be noted that where a shareholder has guaranteed the debts of his corporation for no consideration, the guarantee will generally be considered not to have been given for the purpose of gaining or producing income. ...