Search - consideration

La considération convenue est un pourcentage des honoraires que l'acheteur percevra de la clientèle ainsi acquise pendant une période de cinq ans. 4.     Une considération maximale est fixée. 5.     Aucun montant minimal n'est prévu. ... De plus, si ce doit être l'article 14, vous nous demandez de préciser de quelle manière cet article sera appliqué compte tenu qu'au moment de la vente la considération à recevoir par le vendeur n'est pas connue. ...

For example, by the end of the series of transactions, it would appear that XXXXXXXXXX received strictly shares in XXXXXXXXXX as its consideration for the sale of its shares in XXXXXXXXXX. ... Other Issues It seems peculiar that the preferred shares issued by XXXXXXXXXX in transaction #3 reflect a FMV significantly less than the FMV of the consideration received two days later upon the surrender of those shares by XXXXXXXXXX. ... For example, we would be concerned if a capital gain (i.e. the capital gain that would have arisen had the consideration described in transaction #4 been received in transaction #3) has been converted into a deemed dividend. ...

Principal Issues: 1.Where identical shares are acquired, how is the actual cost of newly- acquired shares taken into consideration? 2.Where the acquisition of newly-acquired shares, how is the 53(1)(j) bump in ACB taken into consideration? ... Therefore, if 1% of the shares sold in 1994 were determined to be newly-acquired shares, only 1% of the paragraph 53(1)(j) adjustment will be taken into consideration in calculating the 1994 capital gain. ...

Where 100% of the shares of a corporation are donated to a private foundation for no consideration, will the foundation be subject to revocation of its charitable registration pursuant to paragraph 149.1(4)(c) of the Act? ... Paragraph 149.1(4)(c) will not apply provided not more than 5% of the shares of the corporation have been acquired by the foundation for consideration. 3. ... This deeming rule will apply only where the foundation has not purchased or otherwise acquired for consideration more than 5% of the issued shares of any class of the corporation. ...

The ETA contemplates the application of the GST based on the value of the consideration for a taxable supply. ... Therefore, it must be determined if the amount charged by the vendor represents consideration only (i.e., "tax-extra") or consideration and tax (i.e., "tax-included"). ... It is relevant to note that in this case, the vendor and purchaser would likely have treated the original billing as consideration without a GST component. ...

Department’s position We agree that the amount of the consideration received by a corporation on the exercise of an option to acquire shares of its capital which will be included in its paid-up capital will depend on the amount which the corporation has added to its legal stated capital account for corporate law purposes. Since the corporate law of most jurisdictions in Canada requires the corporation to add the full amount of any consideration which it receives for the issue of its shares to the relevant stated capital account (with certain exceptions for shares issued to non-arm's length parties or shares issued in exchange for shares of non-arm's length corporations), the amount paid on the exercise of an option to acquire shares will usually form part of the corporation's paid-up capital. ...

Consideration of requests of this nature involves an extensive and fully objective review of the facts of the particular situation and a careful evaluation of the merits of the request to ensure fair and uniform application of established criteria. ... I wish to assure you that you will receive the outmost consideration possible in the resolution of this case. ...

The process ensures that each request receives proper consideration.  ... I would like to assure you that they will receive the utmost consideration possible in the resolution of their case. ...

Consideration of requests of this nature involve an extensive and fully objective review of the facts of the particular situation and a careful evaluation of the merits of the request to ensure fair and uniform application of established criteria. ... I wish to assure you that you will receive the utmost consideration possible in the resolution of their cases. ...

Paragraph 3 of the Bulletin defines a gift, for purposes of the Income Tax Act as "a voluntary transfer of property without consideration".  ... No valuable consideration or benefit of any kind to the donor, or anyone designated by the donor, may result from the payment. ...