Search - consideration

X transfers the Class C shares to a newly-incorporated corporation of which he is the sole shareholder ("Holdco") in consideration for common shares, electing under s. 85(1). ...

If the emphyteusis is made for consideration, the sum so provided, whether payable in a lump sum or by instalments, is considered as proceeds of disposition of a right of emphyteusis or of part or all of the property subject to the emphyteusis. ...

If the emphyteusis is made for consideration, the sum so provided, whether payable in a lump sum or by instalments, is considered as proceeds of disposition of the proceeds of disposition of a right of emphyteusis or of part or all of the property subject to the emphyteusis. ...

13 August 2013 External T.I. 2012-0471401E5 F- FMV- partnership interest-- summary under Other Summary Under Tax Topics- General Concepts- Fair Market Value- Other deferred tax liability re deferred (s. 34) partnership income recognition reduces partnership interest FMV A partner of a professional partnership which has elected under s. 34 to exclude work-in-progress from its income transfers his partnership interest to a corporation in consideration for preferred shares, utilizing the s. 85(1) election. ...

16 February 2016 External T.I. 2015-0618601E5- Earned or Unearned Revenue-- summary under Subsection 56.4(2) Summary Under Tax Topics- Income Tax Act- Section 56.4- Subsection 56.4(2) no deferral of lump sum received on signing 15-year supplier loyalty agreement The taxpayer received a lump-sum payment (the “Payment”) from a major supplier (“ACo”) in consideration for entering into a supplier loyalty agreement (the “Agreement”). ...

16 February 2016 External T.I. 2015-0618601E5- Earned or Unearned Revenue-- summary under Paragraph 12(1)(x) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x) lump sum received on signing 15-year supplier loyalty agreement was immediately recognized inducement The taxpayer received a lump-sum payment (the “Payment”) from a major supplier (“ACo”) in consideration for entering into a supplier loyalty agreement (the “Agreement”). ...

…[W]e have referred this matter…for [Finance’s] consideration in the finalization of the proposed legislation. ...

Before paraphrasing the requirements under s. 60(1)(j)(i) for such a deduction, CRA stated: a foreign plan will be considered to be a superannuation or pension plan where contributions are made to the plan by or on behalf of the 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 payment on or after the employee’s retirement. ...

If it chooses to wait until the consideration for the receivables is payable and include the receivables in the beneficiary's return, subsection 70(3) may apply if an election is made before the expiry of the time allowed in subsection 70(2). ...

If it chooses to wait until the consideration for the receivables is payable and include the receivables in the beneficiary's return, subsection 70(3) may apply if an election is made before the expiry of the time allowed in subsection 70(2). ...