Search - consideration

Other Comments Nothing in this letter should be construed as implying that the CRA has agreed to, reviewed or made any determination in respect of any tax consequences in respect of: (a) the fair market value of any property referred to herein; (b) whether the Proposed Transactions described herein, other than the Proposed Business Transfer, would be undertaken for fair market value consideration; (c) the characterization and tax residency of any entity; (d) any foreign income tax consequences, including whether a rollover provision applies under the Foreign Act; (e) whether any property referred to herein is a “taxable Canadian property”, within the meaning of subsection 248(1), or whether any disposition thereof, including a deemed disposition, could give rise to a taxable capital gain; (f) the potential application of subsection 245(2) to re-determine the tax consequences confirmed in the Rulings given above; or (g) any other tax consequences relating to the facts, Proposed Transactions and additional information described herein, other than those specifically described in the Rulings given above. ...

In determining whether any location visited by a Staff could be a RPE, consideration should be given as to how often a particular townhouse complex or apartment building is visited, and not any individual unit located within the townhouse complex or apartment building. ...

The terms of the settlement provide, among other consideration, for Periodic Payments commencing XXXXXXXXXX, in the amount of XXXXXXXXXX$XXXXXXXXXX per month, increasing by XXXXXXXXXX% annually, guaranteed until the later of XXXXXXXXXX (when the Claimant would turn age XXXXXXXXXX if he dies prior to that date) and the Claimant’s death (XXXXXXXXXX Certain Monthly Payments). 18. ...

Z taking into consideration the application of the deeming rule in subparagraph 120.4(1.1)(b)(ii)? ...

It is important to note the determination of the ACB of the beneficiary’s capital interest in paragraph 107(1)(a) as described above, does not apply if any part of the interest was acquired for consideration and the trust is non-resident at the time of the disposition. ...

Consideration should be given to whether any particular estate could be deemed to be resident in Canada pursuant to section 94. 3 Subsection 107(5) provides that subsection 107(2.1) applies (giving rise to a taxable distribution) and subsection 107(2) does not apply “in respect of a distribution of a property (other than a share of the capital stock of a non-resident-owned investment corporation or property described in any of subparagraphs 128.1(4)(b)(i) to (iii)) by a trust to a non-resident taxpayer (including a partnership other than a Canadian partnership)) in satisfaction of all or part of the taxpayer's capital interest in the trust.” ...

De manière générale, les alinéas 7(1)b), b.1), d) et d.1) L.I.R. s’appliquent lorsque l’employé ou une personne avec laquelle il a un lien de dépendance obtient une contrepartie en considération des droits afférents aux titres dont l’employé a disposé. ...

La Reine (footnote 2), la Cour a confirmé qu’il est nécessaire de procéder à une évaluation objective du test d’objet prévu au paragraphe 83(2.1) L.I.R, qui ne peut s’effectuer qu’en prenant en considération toutes les circonstances pertinentes d’une situation donnée. ...

Lita Krantz, CPA, CA Manager Tax Credits and Ministerial Issues Business and Employment Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch FOOTNOTES Note to reader: Because of our system requirements, the footnotes contained in the original document are shown below instead: 1 See Health Canada’s webpage titled “Regulatory considerations on the classification of non-medical masks or face coverings: Notice to industry.” 2 See the Canadian Centre for Occupational Health and Safety webpage titled “Respirators, Surgical Masks, and Non-Medical Masks” at www.ccohs.ca/images/products/pandemiccovid19/pdf/masks.pdf 3 See the WHO webpage titled “Coronavirus disease (COVID-19): Masks” at www.who.int/emergencies/diseases/novel-coronavirus-2019/question-and-answers-hub/q-a-detail/coronavirus-disease-covid-19-masks and page 4 of the PDF document titled “Mask use in the context of COVID-19” at the following link: www.who.int/publications/i/item/advice-on-the-use-of-masks-in-the-community-during-home-care-and-in-healthcare-settings-in-the-context-of-the-novel-coronavirus- (2019-ncov)-outbreak PROTECTED B PROTECTED B ...

The gifts will be formally documented through a written act of gift and no consideration will be received by Mr. ...