Search - consideration

An individual ("Individual A") has given consideration under an agreement to an exploration corporation ("B Co. ... Our Views It is our view that, in the above-noted situation, B Co. may renounce its qualified resource expenses to Individual A in respect of the flow- through shares which have been transferred to his RRSP, to the extent of the amount of consideration referred to in 1 above, even though Individual A is no longer the holder of such shares at the time of the renouncement. ...

In order to meet the requirement of paragraph 85(1)(b) of the Act that the agreed amount cannot be less than the fair market value of the consideration (other than share consideration) received by the transferor, the transferor issues a promissory note to the transferee corporation, having a principal amount and fair market value equal to the amount by which the amount of the mortgage exceeds the UCC of the depreciable property. ...

Department's Position Whether or not a foreign affiliate employs more than five full-time employees in the active conduct of its business is a question of fact and in order to make this determination it would be necessary to review all the facts surrounding the particular situation under consideration. ... Generally, it does not matter what facet of the business the employee is engaged in, provided all of the employee's duties as such are directly related to the active conduct of the business under consideration. ...

Because the shares of Opco I are not grandfathered, he believes it will be in his interest to take back fixed-value preferred shares from the amalgamated company as consideration for the shares of Opco I and to take back common shares from the amalgamated company as consideration for Opco II. ...

Consideration of requests of this nature involves an extensive and fully objective review of the facts of the particular situation, and a careful evaluation of the merits of the request to ensure fair and uniform application of established criteria. ... I wish to assure you that she will receive the utmost consideration in the resolution of her case. ...

Consideration of requests of this nature involves an extensive and fully objective review of the facts of the particular situation by senior department officials in Head Office. ... I can assure you that you will receive the utmost consideration possible in the resolution of your case. ...

(In the case of Target shares acquired by Parent, Parent issues its shares to TCC in exchange for the issuance by TCC of TCC shares to Parent, which TCC shares are then given by Parent as consideration for the Target shares acquired by it.)? ... In applying the tests in subparagraph 88(1)(c.4)(iii), the TCC shares were not received as consideration for the acquisition of shares of NewTarget (subsidiary) by TCC or Parent (which are, respectively, the taxable Canadian corporation and the parent referred to in subparagraph 88(1)(c.4)(iii)). ... The redeemable preferred shares of NewTarget are redeemed for cash consideration.? ...

As consideration for the transfer, Holdco A will receive non-voting, non-participating, fixed-value preferred shares of Realco. ... As consideration for the share redemptions, Realco will issue a demand promissory note to Opco. 6. ... As consideration for the share redemptions, Opco will issue a demand promissory note to Realco. 7. ...

(footnote 1) Qualifying revenue means the inflow of cash, receivables, or other consideration arising in the course of the ordinary activities of the eligible entity in Canada in a particular period. ... Not typical of the normal activities or risks inherent in the normal operations of the entity o Consideration should be given to the nature of the services or products offered by an entity and the normal environment in which it operates. c. Primarily out of the control of owners or management o Consideration should be given to the extent that inflows are influenced by the decision of owners or management. ...

Consideration for the transfer consisted of shares of Corporation Z, (equal to 66 2/3% of the value of the shares of Corporation X transferred to Corporation Z), and assumption by Corporation Z of debt owing by Mr. ... Further, since all or substantially all of the consideration received by Mr. ... A from Corporation Z in respect of the shares of Corporation X was not shares of Corporation Z (because 33 1/3% of the consideration consisted of assumption of debt owing by Mr. ...