Search - consideration

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. ...

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 he will receive the utmost consideration possible in the resolution of his case. ...

" This presupposes that consideration was given for family support obligations. ... In this regard, family support obligations and household expenses do not form part of the consideration given. ... The case is of interest not only from the finding that no consideration flowed from the performance of household services and chores by the transferee, but also from the standpoint that deposits were made to a joint bank account from which mortgage and lease payments were made. ...

In your particular situation, the quit claim signed by the farmer in consequence of the "Consideration Agreement", facilitated the agreement and not any foreclosure action. ... The nature of the transaction was one where property was transferred to the bank for consideration. ... -Our statement was made in conjunction with a statement we made that "if the guarantee has been given for adequate consideration, it will generally be considered to have been given for the purpose of gaining or producing income. ...

He received no consideration for making the guarantee. 2. XXXXXXXXXX. 3. ... If the guarantee has been given for adequate consideration, it will generally be considered to have been given for the purpose of gaining or producing income. ... The Department's position regarding guarantees or loan for inadequate consideration has been challenged successfully in such cases as Business Art Inc. v. ...

Would our views change if instead of a non-interest bearing loan services were provided for less than fair market value consideration. ... Whether our views would change if Canco provided services to LLC1 for no consideration rather than issuing a non-interest bearing loan. ... It would seem reasonable to be of the view that services provided to LLC1 for no consideration would result in an increase in fair market value of the shares of LLC1. ...

Current content is correct but consideration should be given to expanding discussion in future publications. ... Because both parents were residing together prior to the death, the deceased individual could never make a claim on line 305 for a child because consideration must first be given to a claim for a spouse or common-law partner under paragraph 118(1)(a) of the Act (line 303). ... The additional content could give consideration to such issues as marital status, living arrangements, payment of child support and prior claims for amounts by the deceased under paragraphs 118(1)(b) and 118(1)(b.1) of the Act. ...

The liability is equal to the lesser of the difference between the fair market value of the property transferred and the consideration given for the property, and the transferor's liability for the taxation year in which the property was transferred, or any preceding taxation year. ... The time when the assessment happens to take place is a consideration irrelevant to the statutory scheme. ... The spouse's liability would be the lesser of (a) the amount owing by the transferor, and (b) the difference between the fair market value of the property transferred and the consideration given for the property. ...

The definition of "flow-through share" in subsection 66(15) of the Act requires that a share be issued to a person by a principal-business corporation "under an agreement in writing (emphasis added) entered into... after February 1986, under which the corporation agrees for consideration that does not include property... a) to incur, in the period that begins on the day the agreement was made and ends 24 months after the end of the month that includes that day, Canadian exploration expenses or Canadian development expenses in an amount not less than the consideration for which the share is to be issued, and b) to renounce,... the Canadian exploration expenses or Canadian development expenses so incurred by it not exceeding the consideration received by the corporation for the share,... ...

Reasons FOR POSITION TAKEN: The person is receiving consideration for providing services. ... These paragraphs respectively includes the following comments: "Amounts received as gifts, that is, voluntary transfers of real or personal property without consideration, are not subject to tax in the hands of the recipient. However, when by virtue of an office or employment a voluntary payment or other valuable transfer or benefit is received by an employee from an employer, or from some other person the amount of the payment or other valuable consideration is generally included in income pursuant to subsection 5(1) or paragraph 6(1)(a).... ...