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With respect to the above situation, we have given consideration as to whether the attendance at the conference by the directors without charge represents remuneration in the nature of directors' fees for the purposes of paragraph 6(1)(c) of the Act (the Act). In this regard, such remuneration normally represents consideration that is for the benefit of the directors personally. ... We also wish to mention that in the above situation, it is our view that even though each of the directors of the non-profit corporation may only receive nominal consideration for the services they provide (or perhaps no consideration), it our view that they could nonetheless be considered to be holding an office or employment as a consequence of the definition in subsection 248(1) of the Act. ...

In general, a "gift" for purposes of the Income Tax Act ("the Act") means a voluntary transfer of the donor's property without valuable consideration to the donor. ... Similarly, the purchase of donated property or raffle tickets generally does not result in a gift to the charity as the purchaser is receiving consideration for the amount paid. Should an individual choose to pay more than fair market value for a property or other advantage in order to benefit a charity, a gift may be recognized for tax purposes if the value of the consideration and other advantages to the individual fall within the limits stipulated in the draft legislation. ...

Accordingly, it should not, in our view, constitute consideration for a donation made by the employee. ... Your question is whether the entry into the draw constitutes consideration for those employees who actually make donations. Our Comments As stated in paragraph 3 of our Interpretation Bulletin IT-110R3, a gift, for the purposes of sections 110.1 and 118.1 of the Income Tax Act (the "Act"), is a voluntary transfer of property without valuable consideration. ...

If farmer transfers assets to corp including A\R does he report income no matter the consideration? ... Position: 1. 98(5) will apply provided corporate transferee continues to carry on the business of the partnership and uses the partnership property. 2.Income no matter nature of the consideration. 3.Income to partners when realized. ... In this regard we offer the following general comments: (1) It is our opinion that where all the partners in a partnership have transferred their partnership interests to a corporation, subsection 98(5) will apply to the dissolution of the partnership provided the corporate transferee continues to carry on the business of the partnership, using the partnership property formerly belonging to the partnership. (2) Where a taxpayer using the cash method of reporting income transfers all his accounts receivable to a corporation for any consideration that taxpayer would pursuant to subsection 28(5) of the Act include in income the fair market value of amounts received in satisfaction of the debts at the time he ceases to carry on the business of farming. ...

Reasons: Loans were non interest bearing and no adequate consideration received. ... In the situation you described, the loan was non-interest bearing and you do not indicate that any other adequate consideration was received in respect of the loan. ... Whether in a specific case adequate consideration in respect of a loan was received is a question of fact which can only be determined after all the facts and details have been established and reviewed. ...

As sole consideration for the transfer, A Ltd. issues one additional common share to Mr. ... A as consideration for the capital property transfer to it is greater than the fair market value of the transferred property. ... However, it is our view that a benefit may be conferred on a shareholder where the shares taken back by the shareholder as consideration are of a different class or if there are other shareholders of the corporation. ...

On the second page, first paragraph of "Administrative Considerations", it may be clearer to state that employees must return to work for a period equal in time to the period they were on leave.  ... On the third page, fourth paragraph under "Administrative Considerations", the three month leave must be used for full-time attendance at a designated educational institution.  ... On the third page, last paragraph under "Administrative Considerations", there is no prohibition in the Income Tax Act against reimbursing the employee for such costs as tuition or text books.  ...

Father will receive no consideration from Daughter on the transfer. 5. ... As consideration, Father will receive a partnership interest in FarmPart. ... As consideration, Son will receive a partnership interest in FarmPart. ...

Accordingly, the Fee is not a payment made by the borrower in respect of borrowed money as consideration for a reduction in the rate of interest payable for purposes of subsection 18(9.1). ... Paragraph 18(9.1)(c) Paragraph 18(9.1)(c) refers to payments made as consideration for a reduction in the rate of interest payable by the taxpayer on the debt obligation. ... Accordingly, the Fee is not, in our view, a payment made by B Co in respect of borrowed money as consideration for a reduction in the rate of interest payable. ...

As indicated in paragraph 3 of Interpretation Bulletin IT-110R2 (a copy of which is enclosed), a gift is a voluntary transfer of property without valuable consideration. A gift can be said to have been made where all of the following conditions are satisfied: (a)property (usually cash) is transferred by a donor to a registered charity; (b)the transfer is voluntary; and (c)no consideration or benefit accrues to the donor or to anyone designated by the donor as a result of the transfer. ... The first condition is not met as the purported donation is made to retailers of kosher-approved food products which are not registered as charities; the second condition is not met as the purported cash donation is part of the cost of the food products and is not made voluntarily; and the third condition is not met as the purported donation is not without consideration since you receive food products in exchange for your donation. ...