Search - consideration

No. 2, p. 11, ¶1062)-- summary under Subsection 80(5) Summary Under Tax Topics- Income Tax Act- Section 80- Subsection 80(5) Where receivables are transferred to the debtor corporation in consideration for treasury shares, s. 80 applies if the fair market value of the shares is less than the principal amount of the debt. ...

7 January 2004 External T.I. 2003-001953-- summary under Subsection 108(7) Summary Under Tax Topics- Income Tax Act- 101-110- Section 108- Subsection 108(7) If a trust is established by contributions from two or more unrelated persons and those unrelated persons are beneficiaries of the trust, their respective interests in the trust would be considered to have been acquired for consideration. ...

(Tax Window, No. 17, p. 6, ¶1765)-- summary under Disposition of Property Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Disposition of Property A 99-year lease of residential suites by a condominium corporation to non-members in consideration for substantial up-front payments and nominal annual payments thereafter will be considered to be a disposition. ...

(Tax Window, No. 8, p. 10, ¶1424)-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition Where a taxpayer receives treasury preferred shares of a corporation in consideration for the disposition to the corporation of its common shares, a question may arise as to whether there has been a disposition if the preferred shares are convertible to common shares. ...

(Tax Window, No. 3, p. 26, ¶1232)-- summary under Subparagraph 152(4)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4)- Paragraph 152(4)(a)- Subparagraph 152(4)(a)(ii) RC may revise paragraph 14 of IT-270R2 to take into consideration s. 152(4)(b)(iv). ...

(Tax Window No. 27, p. 5, ¶2321)-- summary under Paragraph 12(1)(g) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(g) S.12(1)(g) does not apply where the consideration received for the sale of software includes a note the timing of payment of which depends on the revenue produced from the exploitation of the software. ...

(Tax Window, No. 29, p. 4, ¶2446)-- summary under Canadian Manufacturing and Processing Profits Summary Under Tax Topics- Income Tax Act- Section 125.1- Subsection 125.1(3)- Canadian Manufacturing and Processing Profits In determining whether the manufacturing and processing deduction is available to the producer of a television show, the important consideration is whether the contract between the producer and the broadcasters is a contract for sale or for services. ...

(June 1990 Access Letter, ¶1250)-- summary under Paragraph 20(1)(m) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(m) The portion of an up-front fee received by a bank in consideration for a granting in interest rate cap is included in its income under s. 12(1)(a)(i) and is deductible under s. 20(1)(m)(ii). ...

13 November 1992 T.I. 923187 (September 1993 Access Letter, p. 423, ¶C144-239)-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition Where a subscriber to an RESP names another person's child as a beneficiary in consideration of the receipt of a lump sum, the subscriber will thereby be disposing of a property giving rise to a capital gain. ...

17 September 1997 External T.I. 9721415- INTERACTION OF SUBSECTION 55(2) & DIVIDEND REFUNDS-- summary under Subsection 55(2) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2) The fact that a dividend refund has been received by the payor of a dividend is not normally relevant to consideration of the following expression: "that is not refunded as a consequence of the payment of a dividend to a corporation where the payment is part of the series of transactions or events". ...