Search - consideration

" It does not appear that circumstances have changed and no similar case has come before the courts for their consideration since that time. ...

The Note was issued in XXXXXXXXXX to Foreign LP by an arm's length party in consideration for the sale of land owned by Foreign LP. ...

Dès lors que l’activité du contribuable comporte un aspect personnel, il est essentiel de prendre en considération tous les faits entourant l’activité du contribuable afin de déterminer si elle est exploitée de manière suffisamment commerciale. ...

None of the issued preferred shares will at any time during the implementation of the proposed transactions be: (a) subject to any secured undertaking of the type described in paragraph 112(2.4)(a) of the Act; or (b) issued for a consideration that includes: (i) an obligation of the type described in subparagraph 112(2.4)(b)(i) of the Act, other than an obligation of a corporation that is related (otherwise than by reason of a right referred to in paragraph 251(5)(b) of the Act); or (ii) any right of the type described in subparagraph 112(2.4)(b)(ii) of the Act. 19. ...

Throughout this advance income tax ruling, the singular should be read as plural and vice versa where the circumstances so require: (a) “Employee” means the employee of ForCo, more fully described in paragraph 9 below; (b) “Employment Agreement” means the agreement entered into by and between Employee and ForCo on XXXXXXXXXX which establishes the employee/employer relationship between them; (c) “ForCo” means XXXXXXXXXX, a corporation more fully described in paragraph 4 below; (d) “Foreign Parent” means XXXXXXXXXX, a corporation more fully described in paragraph 1 below; (e) “Master Agreement” means the agreement entered into by and between Foreign Parent and a Member, more fully described in paragraph 2 below; (f) “Member” means a corporation or other type of entity that has entered into a Master Agreement with Foreign Parent; (g) “Proposed Transactions” means the transactions described in paragraphs 11 to 14 below; (h) “Service Contract” means the contract entered into by and between Foreign Parent and ForCo on XXXXXXXXXX for the provision of services in Canada by ForCo in respect of the Canadian Members of Foreign Parent, more fully described in paragraph 6 below; (i) “Service Fee” means the fees payable by Foreign Parent to ForCo as consideration for services rendered by ForCo under the Service Contract; and (j) “Treaty” means the Canada-U.S. ...

The Lossco Series III Preferred Shares will not at any time during the implementation of the Proposed Transactions be: (a) the subject of any undertaking that is referred to in subsection 112(2.2) as a “guarantee agreement”; (b) the subject of a dividend rental arrangement; (c) the subject of any secured undertaking of the type described in paragraph 112(2.4)(a); or (d) issued for consideration that is or includes: (i) an obligation of the type described in subparagraph 112(2.4)(b)(i), other than an obligation of a corporation that is related (otherwise than by reason of a right referred to in paragraph 251(5)(b)); or (ii) any right of the type described in subparagraph 112(2.4)(b)(ii). 33. ...

31 July 2012 External T.I. 2012-0449871E5 F- Attribution rules- transfer to corporation Unedited CRA Tags 74.4(2); 74.4(3) Principales Questions: In a situation where the purpose test set out in subsection 74.4(2) is met with respect to a transfer of property by X, how would be computed the amount to be included in X's income by virtue of subsection 74.4(2) after the transfer of the excluded consideration received by X from the corporation in favour of another corporation controlled by X? ...

With respect to Scenario 4, we assume that the redemption value of the preferred shares of Divco is equal to the fair market value of the consideration received by Divco upon the issuance of the shares. ...

The Newco Preferred Shares which will be issued as described in 15 above, will not be, at any time during the implementation of the Proposed Transactions: (a) the subject of any undertaking that is referred to in subsection 112(2.2) as a "guarantee agreement"; (b) the subject of a dividend rental arrangement; (c) the subject of any secured undertaking of the type described in paragraph 112(2.4)(a); or (d) issued for consideration that is or includes: A. an obligation of the type described in subparagraph 112(2.4)(b)(i), other than an obligation of a corporation that is related (otherwise than by reason of a right referred to in paragraph 251(5)(b)); or B. any right of the type described in subparagraph 112(2.4)(b)(ii). 25. ...

We were not advised of any other activity that would require our consideration. ...