Search - consideration

Since you believe that this is an inappropriate result, we will forward a copy of your letter to the Department of Finance for their consideration. ...

Should you require further assistance with respect to the particular facts of your case, you should refer these to the tax services office for the individual involved for their consideration and comment. ...

Specifically, clause 256(7)(b)(iii)(B) deems control of a predecessor corporation to have been acquired unless if one person had acquired all of the shares of the new corporation received by the shareholders of the predecessor corporation on the merger in consideration for their shares of the predecessor corporation, that person would have acquired control of the new corporation. ...

In general, the definition states that a "periodic pension payment" does not include payments out of a RRIF where the total of all payments under the RRIF at, or before, the time of payment and in the calendar year exceeds the greater of: (a) twice the amount that would be the minimum amount under the fund for the year, and (b)10% of the amount that would be the fair market value of the property held in connection with the fund at the beginning of the year if all property transferred in the year and before that time to the carrier of the fund as consideration under the fund had been transferred immediately before the beginning of the year and if the definition "minimum amount" in paragraph 146.3(1)(b.1) of the Income Tax Act were applicable with respect to all RRIFs. ...

In general, the definition states that a "periodic pension payment" does not include payments out of a RRIF where the total of all payments under the RRIF at, or before, the time of payment and in the calendar year exceeds the greater of: (a) twice the amount that would be the minimum amount under the fund for the year, and (b) 10% of the amount that would be the fair market value of the property held in connection with the fund at the beginning of the year if all property transferred in the year and before that time to the carrier of the fund as consideration under the fund had been transferred immediately before the beginning of the year and if the definition "minimum amount" in paragraph 146.3(1)(b.1) of the Income Tax Act were applicable with respect to all RRIFs. ...

You ask if the organization would be taxable based on a consideration of the interaction of paragraphs 149(1)(f) and 149(1)(l) of the Act. ...

Pursuant to paragraph (k) of that definition, a plan that is an SDA is excluded from consideration as an RCA. ...

DEPARTMENT'S POSITION Paragraph 3 of the Special Release to IT-110R2 states: "a gift for purposes of sections 110.1 and 118.1 is a voluntary transfer of property without valuable consideration". ...

The fact that it is the employer and not the employees who initiates the arrangement would not be sufficient to remove it from consideration as an SDA. ...

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. ...