Search - consideration

XIII tax, the Directorate stated: [T]he Reimbursements would be made pursuant to the Agreement in return for equivalent consideration paid by USCo to CanCo’s employees. ...

Only amounts resulting in an inflow of cash, receivables or other consideration are included in qualifying revenue, therefore, an eligible entity would not be able to gross up their qualifying revenue by a notional amount. ...

On the other hand, if it indeed was a sublease then, given that “the only parties to the sublease are the sublessor and the subtenant” it would be plausible that the sublease took effect before the deadline, unless further considerations were engaged, for example, the sublease contained a condition stipulating that the agreement would not take effect until the signature of the landlord was procured. ...

However, the Directorate noted the example provided in the Explanatory Notes for the GAAR amendments of a surplus-stripping transaction of Jane in which she realized a capital gain on a dirty s. 85 exchange of her Opco shares, transferred her stepped-up Opco shares to another corporation controlled by her (Buyco) in consideration for a Buyco note, with Opco then dividending its earnings to Buyco for application in repaying the note. ...

However, the Directorate noted the example provided in the Explanatory Notes of a surplus-stripping transaction of Jane in which she realized a capital gain on a dirty s. 85 exchange of her Opco shares, transferred her stepped-up Opco shares to another corporation controlled by her (Buyco) in consideration for a Buyco note, with Opco then dividending its earnings to Buyco for application in repaying the note. ...

Among other considerations, it noted that Art. 18(2) does not provide a specific timeline for making such a request and that the Canada-Italy Treaty contains no provision extending the timeframe for a refund request in this regard (and noted, somewhat in contrast, Art. ...

26 February 2025 Internal T.I. 2023-0985151I7 F- Remboursement de frais juridiques par un actionnaire à sa société / Reimbursement of legal fees by a shareholder-- summary under Legal and other Professional Fees Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Legal and other Professional Fees the vendor’s agreed reimbursement of the sold corporation’s legal costs of a failed suit in consideration for a dividend had the suit succeeded, likely was non-deductible An individual disposed of all the shares of his corporation to an arm's length purchaser, with the exception of a single preferred share. ...

Therefore, Canco would compute its...qualifying income and qualifying losses, and its foreign non-business tax credit, without taking into consideration the...net mark-to-market loss on the Investments. ...

Therefore, Canco would compute its...qualifying income and qualifying losses, and its foreign non-business tax credit, without taking into consideration the...net mark-to-market loss on the Investments. ...

3 June 2013 Internal T.I. 2012-0468131I7- Participating debt interest-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) deductible interest on subordinated convertible debt with participating interest payble in prefs The Canadian taxpayer issued Contracts to its wholly-owning non-resident parent ("ForParent") as consideration for its purchase from ForParent of shares. ...