Search - consideration

“Acquisition of share capital” Shares of a corporation can be issued at any time, for any consideration. ... Thus, a shareholder of a corporation usually acquires, for a consideration, the shares that entitle him to the profits of the corporation. This is to be contrasted with the beneficiaries of a trust who need not provide valuable consideration in order to receive their beneficial interest in the trust. ...

The amounts could also be considered as an inducement for the purposes of paragraph 12(1)(x) as the contractor is obliged to release the licencee from any claims as consideration for the receipt of the amount. ... The terms of the Release make it clear that XXXXXXXXXX received the payment from the Trust in consideration for the reduction of the contract and in consideration for XXXXXXXXXX releasing each other from any claims in respect of this reduction. ... Consequently, it is arguable that the Lost Opportunity Amount represents an inducement for the purposes of paragraph 12(1)(x) as XXXXXXXXXX was obliged to act in a certain manner as consideration thereof. ...

The sponsor is entitled to all of the benefits or consideration that a participant is entitled to independent of whether the sponsor decides to take advantage of them or transfer them to another person. ...

Position TAKEN:refer to assessing per prior instructions Reasons FOR POSITION:routine instructions August 30, 1994 Head Office Head Office Enquiries and Taxpayer Rulings Directorate Assistance Division (613) 957-8953 Attention: Norm O'Donnell T1 Returns & Guides 941949 XXXXXXXXXX We are forwarding for your consideration a referral from the Halifax District Office relating to the deduction available under subsection 146(8.2) of the Income Tax Act (the "Act") where a taxpayer wishes to withdraw excess contributions from an RRSP. ...

Gillman Attention: XXXXXXXXXX August 29, 1994 Dear Sirs: Re: Subsection 127(10.1) of the Income Tax Act (the "Act") Investment Tax Credit within an Associated Group of Companies Your letter of December 23, 1993 to the Vancouver District Office of Revenue Canada, Customs, Excise and Taxation (the "Department"), was forwarded to us for consideration and reply. ...

However, while drawing benefits he participated in a job creation program which increased his weekly UI benefit by $XXXXXXXXXX  Factors for consideration in determining the taxability of the additional $XXXXXXXXXX per week include the following: XXXXXXXXXX lived on the reserve, the duties were performed on the reserve, and the employer was located on the reserve. ...

For your consideration of this remission request, we provide the following comments: To qualify, a taxpayer must be a registered Indian or be entitled to become a registered Indian. ...

We have edited a copy of your draft publication which is enclosed for your consideration. ...

You requested our comments whether losses arising from loan guarantees given by the above corporation on behalf of U.S. corporations which it controls, for no or inadequate consideration, would be deemed to be nil by subparagraph 40(2)(g)(ii) of the Income Tax Act (the "Act") on the basis that the guarantees were not given for the purpose of gaining or producing income. 21(1)(b) Accordingly in our view 24(1) The exception in paragraph 6 of IT-239R2  and paragraph 7 was established to address specific tax policy concerns.  ...

Should you have an actual case under consideration we suggest that you request a ruling.  ...