Search - consideration

A tax shelter promoter is any person who, in the course of a business, sells or issues, or promotes the sale, issuance or acquisition of, the tax shelter, acts as an agent or adviser in respect of the sale or issuance, or the promotion of the sale, issuance or acquisition, of the tax shelter, or accepts, whether as a principal or agent, consideration in respect of the tax shelter. ...

Normally, we would consider a superannuation or pension fund or plan is one where contributions have been made to the plan by or on behalf of an employer or former employer of an employee in consideration for services rendered by the employee, and the contributions are used to provide an annuity or other periodic payment to the employee on or after the employee's retirement. ...

Nevertheless, the fact that a participant is a shareholder would certainly be taken under consideration, along with all of the other facts and circumstances, in determining whether a plan is an SDA or an RCA and whether contributions to the plan are reasonable. ...

We have forwarded a copy of your letter and our response to the Department of Finance for its consideration of your concerns from a tax policy perspective. ...

Except where fair market value consideration is paid by the spouse or the parties are living separate and apart by reason of a breakdown of their marriage, income earned and capital gains and losses realized on property transferred or loaned from a taxpayer to the taxpayer's spouse (and on property substituted for that property) are generally deemed to be the income, gains or losses of the taxpayer and not of the taxpayer's spouse (the "Attribution Rules"). ...

Paragraph 118.2(2)(q) provides that any premium, contribution or other consideration that the individual or his or her legal representative has paid under a private health services plan for that individual, the individual's spouse or a member of the household with whom the individual is connected by blood relationship, marriage or adoption may be included as a qualifying medical expense. ...

Consistent with CRA position taken in response to 1988 Round Table question. 2006-020869 XXXXXXXXXX James Atkinson CGA (519) 457-4832 January 15, 2007 Dear XXXXXXXXXX: Re: Transfer of Property Prior to Sale of Shares- Paragraph 110.6(14)(f) This is in response to your e-mail of September 29, 2006 inquiring about the application of paragraph 110.6(14)(f) of the Income Tax Act ("Act") where shares have been issued as consideration for property transferred, prior to a sale of those shares. ...

In trying to ascertain the appropriate treatment of an award of damages where some of all such amounts may relate to a loss of office or employment, the courts have taken the view that consideration should be given to whether the damages would have been received if it were not for the loss of office or employment. ...

In consideration of the Assignee making such payments, the Plaintiff agrees to settle her claims against the Defendant. ...

In consideration of the Insurer making such payments, the Claimant agrees to settle her claims against the Defendant. ...