Search - consideration

The determination of whether or not an object has become a fixture requires consideration of the degree of annexation and the purpose of annexation. ...

A would first dispose of his HOLDCO shares in favour of OPCO, in consideration for shares of OPCO with the same tax attributes. ...

Accordingly, it may first be necessary to determine when the employment will terminate before consideration can be given to the tax treatment of benefits that may arise. ...

A taxpayer who for no consideration validly releases or surrenders an income interest in a trust in respect of future payments (not due and payable at the time the release or surrender is executed) and does not direct in any manner who is entitled to receive the benefits, will not be considered to have received any proceeds of disposition for the purposes of subsection 106(2). ...

A Co will subscribe for XXXXXXXXXX Newco Common Shares for a cash consideration of $XXXXXXXXXX. 11. ...

Parmi les éléments à considérer, le fait que le même privilège soit accordé à des employés de la société qui ne sont pas des actionnaires, constituerait un facteur important, même s'il n'est pas le seul pris en considération. ...

The Corporation received $XXXXXXXXXX (hereafter referred to as the "Proceeds") from the Purchaser in consideration for the sale. ...

De plus, nous pouvons considérer la définition suivante qu'attribue le Shorter Oxford English Dictionary au terme " pension ": "an annuity or other periodical payment made, esp. by a government, a company or an employer of labour, in consideration of past services... ...

You argue that it is against the very nature of tax treaties for Canada to insist that a taxpayer file in accordance with the Convention where that results in double taxation, especially where the Article under consideration is the Article for the "Elimination of Double Taxation". ...

(f) In determining the prevailing commercial arm's length interest rate applicable to a loan that is similar to the Loan, could consideration be given to the likelihood of payments of Additional Interest never being made by the Borrower (i.e. the likelihood that the Borrower would never have Excess Cash available)? ...