Search - consideration

C.A.) at p. 876 that: "an instrument is altered in a material particular if the rights and obligations of the parties under it, if effect were given to it in its altered consideration, would be different from that which the law would imply if no alteration had taken place. ...

Such considerations would not have been applicable to the subsection 5907(2.1) election. ...

XXX Evidentiary Considerations XXX If you have any questions in respect to this matter, we would be please to discuss them with you. ...

By virtue of paragraph 95(2)(b) of the Act the income of a controlled foreign affiliate of a taxpayer from services is deemed to be income from a business other than an active business if the amount paid in consideration therefore is deductible in computing the income from a business carried on in Canada by any person in relation to which the affiliate is a controlled foreign affiliate. ...

However, subsections 15(1), 56(2), 245(2) and 214(3) could be considered if the consideration paid by Canco for the non-voting preferred shares exceeds the fair market value thereof. ...

By virtue of paragraph 95(2)(b) of the Act the income of a controlled foreign affiliate of a taxpayer from services is deemed to be income from a business other than an active business if the amount paid in consideration therefore is deductible in computing the income from a business carried on in Canada by any person in relation to which the affiliate is a controlled foreign affiliate. ...

Paragraph 56(1)(a) of the Income Tax Act (the "Act") lists benefits under an EBP as being superannuation or pension benefits which are excluded from consideration under that provision.  ...

In this regard, you have asked us to confirm that Safe Income attributable to a deemed dividend on the redemption of high-low preferred shares that were received as consideration for shares which had a Safe Income entitlement is fixed at the point in time that the preferred shares are issued, and does not change over time in relation to changes in the fair market value of the corporation and its shares. ...

Acquisition of Property in Contemplation of the Transfer If a particular corporation transfers property to a wholly owned subsidiary in consideration for shares and then transfers such shares to a shareholder corporation as part of a butterfly, Revenue Canada Taxation considers that the transfer to the subsidiary is part of an indirect transfer of the property of the particular corporation to a transferee and that paragraph 55(3)(b) would not apply unless the subsidiary is wound up following the transfer of its shares to the shareholder corporation. ...

Concurrently with the issue of the new preference shares, Famco also issues additional common shares to the Son in consideration for a subscription price equal to their fair market value (based on the fair market value of an existing common share of Famco held by the Son). ...