Search - consideration

Après avoir pris cette présomption en considération, dans les cas de jurisprudence suivants, les tribunaux n’ont pas caractérisé les revenus comme provenant d’une d’entreprise: Simone Rita Balz (P. ...

XXXXXXXXXX entered into an administrative services agreement dated XXXXXXXXXX (the “Administrative Services Agreement”) with Canco pursuant to which Canco currently provides, in consideration for a commercially reasonable fee, certain administrative services in respect of other XXXXXXXXXX Funds. ...

Our rulings are based on the Act in its present form and do not take into consideration any proposed amendments thereto. ...

On XXXXXXXXXX, in contemplation of the Proposed Transactions, the Taxpayer incorporated Newco for nominal consideration in exchange for one Newco Common Share. ...

However, this view is subject to the results of your audit concerning the determination and review of all relevant facts and taking into consideration all of our comments as stated herein. ...

., 66 DTC 226 (Tax Appeal Board), le juge mentionne ce qui suit:...The consideration paid for the cancellation of the lease was money earned through the ownership of property and stemmed from a relationship of landlord and tenant... ...

Nos commentaires Projet comportant un risque ou une affaire de caractère commercial Pour déterminer si une transaction quelconque est un projet comportant un risque ou une affaire de caractère commercial, les tribunaux ont établi que toutes les circonstances entourant la transaction doivent être prises en considération et qu'aucun critère unique ne peut être formulé. ...

Financial assistance for total loss suffered by the owner of a home, rental buildings and buildings used for certain businesses Assistance- Under orders issued by the Government of Quebec, a property owner who is entitled to financial assistance for the total loss of his residence or building must assign the land and the residual property in consideration of the financial assistance.- The owner can receive 100% of the standard municipal assessment (land and building), up to a maximum of $100,000 plus 75% of the excess over and above $100,000 if he has suffered a total loss with respect to the following types of properties: Principal Residence- a single-family residence or rental building of three units or less in which the individual resided;- or the housing unit in a rental building of more than three units where the individual resided (in such situations, the individual may receive for that unit the proportion of the municipal assessment for that housing unit, up to a maximum of the amount mentioned above); Rental building- rental spaces in a rental building of more than three housing units where the individual resided (in such situations, the individual may receive for the rental spaces the proportion of the municipal assessment for those spaces, up to a maximum of the amount mentioned above);- rental building of more than three units not inhabited by the owner; Building essential to the survival or the continuation of the operations of specific businesses- buildings covered by Order 973-96 which are not referred to above. ...

As consideration for the purchase of its Class XXXXXXXXXX common shares, XXXXXXXXXX will transfer to Newco all of its assets held at that time, except for an amount of $XXXXXXXXXX in cash, and Newco will assume all of XXXXXXXXXX liabilities. 18.As a result of the distribution of the properties of XXXXXXXXXX described in paragraph 17 above, the net fair market value of the cash or near-cash property and investment property received by Newco, will be equal to or approximate the proportion (the "Newco Proportion") of the net fair market value of all of the cash or near-cash and investment property owned by XXXXXXXXXX, immediately before the transfer, that: (a)the fair market value, immediately before the transfer, of all the shares of the capital stock of XXXXXXXXXX owned by Newco at that time is of (b)the fair market value immediately before the transfer of all the issued shares of the capital stock of XXXXXXXXXX at that time. ...

Only point for consideration was whether the employer could give additional flex dollars to any employee who opts to give up coverage under the wage loss replacement plan to which the employer ordinarily contributes. ...