Search - consideration

., it will not consider the note to be a non-share consideration received on the transfer of assets by the transferor to the transferee. ...

(Tax Window, No. 30, p. 19, ¶2502)-- summary under Paragraph 55(3)(b) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(3)- Paragraph 55(3)(b) An acquisition of property will not normally be considered to have occurred in contemplation of a butterfly reorganization where the acquisition occurred in the ordinary course of the particular corporation's business and would have occurred irrespective whether the butterfly reorganization subsequently occurred, the structure and timing of the acquisition was not affected by butterfly-related considerations, and the acquisition was [not] conditional on completion of the butterfly transactions. ...

However, additional considerations would arise if the proposed trustees were not dealing at arm's length with the plan beneficiaries. ...

If so, then the value of the benefit is the difference between such fair market value and the consideration paid by the shareholder. ...

If so, then the value of the benefit is the difference between such fair market value and the consideration paid by the shareholder. ...

(June 1990 Access Letter, ¶1250)-- summary under Subsection 18(9) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(9) Where an up-front fee is paid by a bank to another financial institution in respect of an interest-rate cap, no deduction may be made in the year of payment in respect of the portion of the fee which may be viewed as consideration for services to be rendered after the end of the year. ...

"6363-1 Foreign Affiliate Deemed Active Business Income")-- summary under Foreign Affiliate Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(1)- Foreign Affiliate A Wyoming limited liability corporation that indirectly was owned 50% by each of two Canadian corporations dealing at arm's length with each other would be a foreign affiliate of the Canadian corporation under consideration, with the result that s. 95(2)(a)(i) would apply to certain interest income earned by the limited liability corporation. ...

26 March 1992 External T.I. 5-913338-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) Where a holding company assumes all of the debt associated with a property acquired by it from its subsidiary, interest on that debt will be deductible provided the property is used by the holding company for the purpose of earning income, even though for purposes of an s. 85(1) election, a substantial portion of that debt was assumed as consideration for a promissory note of the subsidiary rather than as payment for the transferred property. ...

26 March 1992 External T.I. 5-913338-- summary under Subsection 85(1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1) Where a holding company assumes all of the debt associated with a property acquired by it from its subsidiary, interest on that debt will be deductible provided the property is used by the holding company for the purpose of earning income, even though for purposes of an s. 85(1) election, a substantial portion of that debt was assumed as consideration for a promissory note of the subsidiary rather than as payment for the transferred property. ...

5 July 1990 TI AC59710-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt Where a promissory note is given in consideration for services, the acceptance of the note would be considered to be an amount received under s. 12(1)(a) where the note has been accepted as absolute payment for the services, whereas if the note has been accepted as conditional payment, s. 12(1)(a) will apply only when actual payments are made on the note assuming the related services have not yet been performed at that time. ...