Search - consideration

6 September 1994 External T.I. 9420525- DIRECTOR-STOCK OPTIONS-- summary under Subsection 7(5) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(5) Options are received by a director in respect of an employment where the options were granted to the director in consideration for the services to be performed as director. ...

24 September 1996 External T.I. 9627705- DONATIONS/TUITION FEES-- summary under Total Charitable Gifts Summary Under Tax Topics- Income Tax Act- Section 118.1- Subsection 118.1(1)- Total Charitable Gifts Unlike teaching or other training, religious training is not viewed as consideration for purposes of the definition of a gift. ...

24 May 1995 External T.I. 9420675- WYOMING LLCS-- summary under Subsection 85(1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1) An interest in a Wyoming LLC receivable by a taxpayer as consideration for the disposition of shares of a foreign affiliate to the LLC would constitute "shares of the capital stock of the acquiring affiliate" provided that the LLC otherwise qualified as a foreign affiliate of the taxpayer immediately after the disposition. ...

-- summary under Subsection 256(1.1) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(1.1) Where a share has been issued as a stock dividend, the consideration for which the share was issued would be considered to be nil. ...

12 November 2003 External T.I. 2002-0121835- 85(1)- Holdbacks Payable-- summary under Subsection 85(1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1) On a sale by a contractor of its construction contracts to a corporate purchaser, the fair market value of builder's holdbacks assumed by the purchaser would be considered to be non-share consideration for purposes of s. 85(1). ...

9 November 1999 External T.I. 9912655- CONFIDENTIALITY COVENANT-- summary under Paragraph 6(3)(e) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(3)- Paragraph 6(3)(e) The Agency indicated that an amount paid to a dismissed employee to secure a confidentiality agreement would be described by s. 6(3)(e) as consideration for a covenant with reference to what an officer or employee would not do after the termination of the employment. ...

(October 1990 Access Letter, ¶1483)-- summary under Subsection 191(4) Summary Under Tax Topics- Income Tax Act- Section 191- Subsection 191(4) Where an individual transfers shares of Opco to Holdco in consideration for retractable preferred shares whose redemption amount will be determined by a resolution of the directors, the redemption amount will be considered to be a specified amount provided that the directors set the redemption amount prior to the issuance of the shares. ...

(Tax Window, No. 2, p. 5, ¶1187)-- summary under Qualified Small Business Corporation Share Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Qualified Small Business Corporation Share Mortgages held by a developer which were the consideration for sales of its land inventory would not qualify as being used in an active business because the funds tied up in the mortgages are not used in the active business. ...

Profit- Shares Where shares have been issued by a corporation as consideration for real property transferred to it and s. 54.2 does not apply, then if a sale of the capital property would have been on capital account, the sale of the shares generally will be on capital account. ...

A of all the shares of Holdco to a corporation owned by their daughter and son-in-law in consideration for a promissory note bearing a commercial rate of interest gives rise to a deemed dividend under s. 84.1(1)(b) equal to the amount by which the principal amount of the promissory note exceeds the greater of the paid-up capital of the shares of Holdco and their adjusted cost base. ...