Search - consideration

Given the diversity of Canada’s aboriginal peoples, each ASC’s connection to and status in a religious denomination must be considered on a case-by-case basis with consideration to the structure and practices of the particular system of faith of his or her band or community. ... In our view, with consideration to IT-141R and Kraft, the XXXXXXXXXX population would likely constitute a congregation. ...

Accordingly, a rent normally refers to a payment that is consideration for the use or the right to use property for a term, whether fixed in time or otherwise determinable, after which the right of the grantee to the property and to its use reverts to the grantor. ... As you know, the OECD Model Convention defines royalties in paragraph 2 of Article 12 as "payments of any kind received as consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work, including cinematograph films, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience". ...

In XXXXXXXXXX, the taxpayer, in order to protect the property from creditors, transferred the legal title to the property for nominal consideration to a friend with the agreement that the legal title would be reacquired at a later time. ... In XXXXXXXXXX, the taxpayer reacquired the legal title to the property from her friend, also for nominal consideration, in accordance with the agreement. 4. ...

Where a lessor charges a lessee a nominal monthly amount for the use of its automobiles, the CRA will examine the consideration exchanged. ... In this regard, we are aware that it is not uncommon for the use of automobiles to be provided in exchange for non-cash consideration. ...

Although consideration should be given to the availability and quantum of support provided, a person is generally considered to be dependent on an individual if the individual has actually supplied necessary maintenance, or the basic necessities of life (food, shelter and clothing) to the person on a regular and consistent basis. ... In respect of personal tax credits and in consideration of the above, one or both parents may qualify for the amount for infirm dependants age 18 or older under paragraph 118(1)(d) of the Act. ...

Generally, a plan will be considered a superannuation or pension fund or plan where contributions have been made to the plan by or on behalf of an employer or former employer of an employee in consideration for services rendered by the employee and the contributions are used to provide an annuity or other periodic payments on or after the employee's retirement in consideration for his or her employment services. ...

However, pursuant to subparagraph 40(2)(g)(ii), that loss may be deemed to be nil unless it was acquired by the taxpayer for the purpose of earning income or as consideration for the disposition of capital property with whom the taxpayer was dealing at arm’s length. ... (ii) a loss from the disposition of a debt or other right to receive an amount, unless the debt or right, as the case may be, was acquired by the taxpayer for the purpose of gaining or producing income from a business or property (other than exempt income) or as consideration for the disposition of capital property to a person with whom the taxpayer was dealing at arm’s length, […] is nil;” With respect to the example in which the negative yield bond was held on account of income, it is assumed that paragraph 18(1)(a) would not otherwise apply. ...

To determine if a motor vehicle allowance is reasonable, various considerations arise. ... Consideration would need to be given to the reasonable costs that an employee would be expected to incur for actual trips compared to the amount of the allowance paid to the employee. ...

Lorsqu'il s'agit de déterminer le degré de corrélation, d'entrelacement ou d'interdépendance existant entre des opérations commerciales, les facteurs à prendre en considération peuvent inclure les suivants, sans que cette liste soit exhaustive: a) La mesure dans laquelle les deux exploitations ont des facteurs communs qui peuvent être pertinents; b) La question de savoir si l'exploitation se fait dans les mêmes locaux; c) Une exploitation peut exister principalement dans l'intention d'approvisionner l'autre; d) Les entreprises ont des fins d'année financière différentes; e) Le système comptable du contribuable enregistre les opérations des deux entreprises comme s'il s'agissait d'une seule entreprise, ou des registres complets et distincts sont tenus pendant toute l'année. ... Tout d'abord, mentionnons que la liste de facteurs à prendre en considération apparaissant au IT-206R n'est pas exhaustive. ...

Yes, if the fair market value of the policy exceeds any consideration given by the employee for the transfer of the policy. ... In the first scenario, paragraph 6(1)(a) of the Act will include in the income of the employee the amount, if any, by which the fair market value of the policy exceeds any consideration given by the employee for the transfer of the policy. ...