Search - consideration

Depending on whether or not the beneficiary acquired the interest in the trust for consideration and whether or not section 233.4 applies, the beneficiary may need to file Form T1135 “Information Return relating to Foreign Property” under subsection 233.3(3) of the Act. ...

However, in any particular case, there may be other considerations. In all cases, it is a question of fact as to how much, if any, of the excess land is necessary for the use and enjoyment of the housing unit as a residence. ...

As indicated in paragraph 3 of Interpretation Bulletin IT-110R3, Gifts and Official Donation Receipts, a gift is a voluntary transfer of property without valuable consideration. ...

An important consideration is how the land was used during the period of ownership. ...

I trust he will give your comments every consideration. I wish to thank you for bringing your concerns to our attention. ...

.- It is contemplated that Profitco would transfer, on a tax-deferred basis under section 85 of the Act, the Target shares to another wholly-owned subsidiary of Parentco ("Subco") in consideration for High/Low Shares of Subco. ...

A. is that they would not be reasonable expenses of XXXXXXXXXX within the meaning of section 67 of the Act, for we are not able to answer the question: “Would a reasonable business person have contracted to pay such amounts having only business considerations in mind?” ...

Department’s Position The determination of how the foreign affiliate provisions apply to the money lending activities of a financing affiliate is a complex subject, requiring an in-depth understanding of the arrangements under consideration. ...

As stated in paragraph 3 of the attached Interpretation Bulletin IT-339R2, Meaning of “Private Health Services Plan”, a plan (other than one that is provided by means of a contract of insurance with an insurer) must containing the following basic elements of insurance in order to qualify as a PHSP: (a) an undertaking of one person, (b) to indemnify another person, (c) for an agreed consideration, (d) from a loss or liability in respect of an event, (e) the happening of which is uncertain. ...

Facts XXXXXXXXXX Our Opinion As explained in paragraph 2 of Interpretation Bulletin IT-226R, “Gift to a Charity of a Residual Interest in Real Property or an Equitable Interest in a Trust”, a gift is a voluntary transfer (i.e. from the owner of the property to the recipient) without valuable consideration. ...