Search - consideration

The Corporation would typically issue payment dependent unsecured interest bearing notes to individual investors (Lenders) for cash consideration. ... Under subparagraph 40(2)(g)(ii) of the Act, a taxpayer's loss arising from the disposition of a debt is nil unless (i) the debt had been acquired by the taxpayer for the purpose of gaining or producing income from a business or property; or (ii) acquired as consideration from the disposition of capital property in an arm's length transaction. ...

Subparagraphs 212(1)(d)(i) and (iii) of the Act read as follows: 212(1) Every non-resident person shall pay an income tax of 25% on every amount that a person resident in Canada pays or credits, or is deemed by Part I to pay or credit, to the non-resident person as, on account or in lieu of payment of, or in satisfaction of, … (d) …, any payment (i) for the use of or for the right to use in Canada any property, invention, trade-name, patent, trade-mark, design or model, plan, secret formula, process or other thing, whatever, … (iii) for services of an industrial, commercial or scientific character performed by a non-resident person where the total amount payable as consideration for those services is dependent in whole or in part on (A) the use to be made of, or the benefit to be derived from, those services, (B) production or sales of goods or services, or (C) profits, but not including a payment made for services performed in connection with the sale of property or the negotiation of a contract, Given our understanding that the ads would be uploaded to the Website by the US Employees who would also be carrying out all other management and maintenance functions in respect of the Website, in our view, the Advertisers would be paying for services provided by US Publisher such that the Fee would not be considered as the payment for the use of or the right to use in Canada any property. ... The next issue is whether the “total amount payable as consideration for those services is dependent in whole or in part on” any of the criteria listed in clauses 212(1)(d)(iii)(A) to (C) of Act. ... Paragraph 4 of Article XII of the Treaty defines royalties for the purposes of Article XII quite broadly as follows: The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic, or scientific work (including motion pictures and works on film, video tape or means of reproduction for use in connection with television) any patent, trade mark, design or model, plan, secret formula or process, or for the use of, or the right to use, tangible personal property or for information concerning industrial, commercial or scientific experience, and notwithstanding the provisions of Article XIII (Gains), including gains from the alienation of any intangible property or rights described in this paragraph to the extent that such gains are contingent on the productivity, use or subsequent disposition of such rights. ...

If the vote does not confirm that at least ninety percent of the eligible voters want to relocate, the Government’s consideration of the relocation request will stop. 7. ... To help Residential and Commercial Owners make informed legal decisions, the Department will pay legal fees related to consideration of the Department’s written offer detailing relocation assistance and the discontinuation of provincial services. ... To the extent that the amount of the legal fees was not taken into consideration in the calculation of the taxpayer’s income from business or property, paragraph 12(1)(x) will likely apply to include the amount received in the year as income from business or property. ...

" The Court then went on to conclude that neither OBC nor ICS is a "religious order," based on two principal considerations. The first consideration was that there is no expression of faith or of religious purpose of either institution (apart from the educational purpose of each) that would mark the institution, and its members as distinct from the churches or denominations that each serves. ... " The second consideration was that OBC and ICS have their primary purposes in education. ...

The merit of the musician's proposed project is one of the considerations of the panel. ... For instance, you indicate that the merit of the musician's proposed project is one of the considerations for receiving the award; however, it is unclear how much weight is allocated to this factor and which other factors are considered. ... Rather, the candidates are asked to provide certain information for the consideration of the committee; a current curriculum vitae, a one-page biography, a personal artistic statement regarding his/her career and a current audio or video tape presenting a recent performance or performances. ...

Cependant, un seul dividende imposable de 200 $ aurait été inscrit à l’Annexe 55 produite par Opco, en raison d’une erreur de bonne foi du préparateur d’impôt (qui n’aurait pris en considération qu’un seul des deux dividendes imposables de 200 $). ... Le montant obtenu pour l’élément B dans le calcul du CRTG d’Opco à la fin de son Année de perte 2019 serait alors rajusté pour prendre en considération le montant établi dans les nouvelles cotisations pour les Années d’application 2016 et 2017. ... Le montant pour l’élément B dans le calcul du CRTG à la fin de l’Année de perte 2020 serait rajusté pour prendre en considération le montant établi dans une nouvelle cotisation pour chacune de celles-ci. ...

An inter vivos trust will be a personal trust where no beneficial interest in the trust was acquired for consideration payable directly or indirectly to the trust or to a person who has contributed to the trust by way of transfer, assignment or other disposition of property. ...

The holders of the subscription receipts are entitled to acquire treasury shares of the corporation for no consideration provided that a number of conditions are satisfied, including the listing of such shares on a designated stock exchange. ...

The new common shares would typically be issued for a relatively nominal consideration. ...

Further, where Parent does not receive any consideration for undertaking Sub’s activities, we would consider the potential application of various benefit provisions contained in the Act. ...