Search - consideration

In the sample documentation submitted with your request, the individuals did not receive any non-share consideration for the purported transfer of their fishing rights. ...

With respect to subsection 161(2), which concerns the interest to be charged on deficient instalments, section 5300 and subsection 5301(10) of the Income Tax Regulations provide that in determining the “instalment base” (as defined in subsection 161(9) of the Act) on which the instalments required to be paid are calculated (by virtue of subsection 161(4), (4.01) or (4.1) of the Act), the tax payable by a taxpayer is the tax determined before taking into consideration the "specified future tax consequences" (defined in subsection 248(1) of the Act) for the year. ...

We also advise that the issues raised in your letter have been forwarded to the Department of Finance for their consideration. ...

This determination required a review of all relevant connecting factors and consideration as to how much weight should be given to each factor. ...

The Widow will execute a Deed of Disclaimer to release or surrender her discretionary income interest in the Trust for no consideration. ...

XXXXXXXXXX will compensate XXXXXXXXXX for differences between the interest rate and fees specified to be payable under the credit facility and the interest rate and fees agreed to by XXXXXXXXXX as consideration for the assignment. 22. ...

The reason XXXXXXXXXX shareholders who hold shares of XXXXXXXXXX in their RRSPs purchase those shares for cash prior to exchanging them for shares of XXXXXXXXXX is to fit within the exception in subparagraph 88(1)(c.3)(i) for "shares of the capital stock of the parent issued by the parent as consideration for the acquisition of the shares of the capital stock of the subsidiary by the parent". ...

We have advised the Department of Finance of the discrepancy in the income tax treatment to the Insurer of the Maturity Guarantee payment, as described above, for their consideration. ...

(i) At the Effective Time, New Targetco will issue common shares (the "XXXXXXXXXX Shares") to Canco in consideration for Canco's issuing its common shares to the Targetco shareholders. ...

In our view, a note which represents absolute or conditional payment constitutes "consideration for the transferred property" for the purposes of subsection 74.5(1) of the Act.  ...