Search - consideration

Factors taken into consideration to determine if a corporation is engaged in construction includes whether the construction industry would view the corporation's overall activities as construction activities and the use of construction equipment (e.g., trucks, tractor trailers, rollers). ...

La Loi sur les sociétés par laquelle est régie la société, le registre des actionnaires, les statuts et règlements de la société de même que la convention unanime des actionnaires sont des éléments qu'il importe de prendre en considération pour déterminer le contrôle de droit d'une société. ...

Your letter presented the following example for our consideration: Income Trust ABC distributes $1.00 per unit held ($.60 per unit is Other Income and $.40 is Return of Capital). ...

A provides sufficient powers to the liquidator of the succession to have the corporation which issued the Shares redeem all or part of them and to effect a transfer of the Shares to another corporation in consideration for shares of the other corporation (the "Substituted Shares"). ...

Under subparagraph 40(2)(g)(ii) of the Act, a taxpayer's loss arising from the disposition of a debt is nil (and therefore cannot result in a capital loss) unless the debt had been (i) acquired by the taxpayer for the purpose of gaining or producing income from a business or property (other than exempt income); or (ii) acquired as consideration for the disposition of capital property in an arm's length transaction. ...

A would also like to take back non-share consideration on this transfer to the maximum extent possible without being deemed to have received a dividend pursuant to paragraph 84.1(1)(b). ...

13 May 2005 External T.I. 2005-0126531E5 F- Capital Gain Strip/Significant Increase Unedited CRA Tags 55(3)(a)(i) 55(3)(a)(v) Principales Questions: In a given situation, where Holdco's shareholder and Employeeco's common shareholders are not related to each other, Holdco and Employeeco each own 50% of Opco's common shares, Holdco controls Employeeco and owns all Employeeco high-low redeemable preferred shares which Holdco acquired over a 5 year period as consideration for the rollover transfer each year of 10% of its Opco common shares, and Employeeco redeems part of its preferred shares owned by Holdco, whether 55(2) applies? ...

Where the transactions in question relate to an acquisition of an interest in a property which constitutes a CRP, the consideration given for the acquisition of the interest would generally constitute the cost of a CRP to the purchaser [such interest being a CRP under paragraph (g) to the definition thereof in subsection 66(15) of the Act, subject to the exceptions contained therein] and proceeds of disposition of an interest in a CRP to the vendor [in a mineral resource context such proceeds being included in the determination of item F of the cumulative CDE of the vendor as defined under subsection 66.2(5) of the Act, subject to the express exceptions contained therein]. ...

(d) As consideration for the Guarantee, Foreign Bank will pay FA2 a monthly fee (the Guarantee Fee) based on a percentage of the collateral. ...

However, if the Taxpayer was a U.S. citizen, the foreign tax credit in respect of the U.S. tax paid on the Deemed Distribution should be computed giving consideration to subparagraph 4(a) of Article XXIV of the Convention between Canada and the United States of America with Respect to Taxes on Income and on Capital. ...