Search - consideration

Principal Issues: Whether, in a particular situation where a corporation ("USCO") grants to another corporation ("CANCO") options to purchase additional shares of USCO's capital stock and such options are not granted in consideration for services previously rendered, subsection 15(1) would apply to CANCO at the time of the granting of such options and/or at the time of their exercise. ...

The premium paid on the purchase of a bond is added to its ACB, and any amount deducted under ss. 20(14) of the Act reduces the ACB. (3) The owner of a strip bond is required to include the interest that accrued at the end of the anniversary day of the contract (ss. 12(4) of the Act) and that amount is included in the ACB of the bond (ss. 52(1) of the Act. (4) An estate may deduct the amounts payable to a beneficiary and the appropriate T3 or NR4 slips have to be issued. (5) Various considerations. ...

It is a question of fact as to whether the children would be considered to meet the excluded business test with consideration given to the nature, and the labour requirements of Investco’s business. ...

Additional Information To the best of your knowledge and the knowledge of the taxpayers involved, none of the issues under consideration in this request for an advance income tax ruling: is in an earlier return filed by any of the taxpayers or a related person; is being considered by a tax services office or taxation centre in connection with a previously filed return of any of the taxpayers or a related person; is under objection by any of the taxpayers or a related person; is before the courts in respect of any of the taxpayers or a related person; or is the subject of a ruling previously issued by the Income Tax Rulings and Interpretations Directorate to any of the taxpayers or a related person. ...

At the time of transfer of a portion of the property to an adult child for no consideration, where the property has increased in value, a capital gain is determined and the provisions of subparagraph 69(1)(b)(ii) of the Act are applicable. ...

As consideration for the XXXXXXXXXX Bonds and Units, the Bond Trustee transferred to the Corporation the security and foreclosure rights it held in connection with the Bonds. ...

Prior to Aco's XXXXXXXXXX year-end, Aco will acquire all of Bco's shares in Old Prodco for consideration representing the current fair market value of Old Prodco. ...

No other consideration will be paid by Newco for such shares. The addition to the stated capital of the Newco common shares in respect of each such transfer will be equal to the FMV of the Class A preferred shares of Propertyco that were transferred. ...

For instance, you indicate that the merit of the musician's proposed project is one of the considerations for receiving the award; however, it is unclear how much weight is allocated to this factor and which other factors are considered. ...

ACO and BCO will jointly elect in prescribed form and in accordance with subsection 85(6) of the Act to have the provisions of subsection 85(1) of the Act apply to the assignment of BCO Debt in consideration for the issuance of the Preferred Shares. 21. ...