Search - consideration

Qualifying medical expenses, as defined in subsection 118.2(2) of the Act, include a premium, contribution or other consideration paid under a "private health services plan" ("PHSP"), which is defined in subsection 248(1) of the Act. ... Based on our review of the proposed legislative amendments to the Ontario Income Tax Act with respect to the Premium, it is our view that the Premium established under the proposed amendments does not represent consideration paid under a PHSP, but is a tax imposed under the Ontario Income Tax Act. ... Moreover, even if the Premium represented consideration paid under a contract of insurance, it is our view that such a premium would still not qualify for the medical expense tax credit. ...

Qualifying revenue of an eligible entity (eligible employer) for purposes of the Canada Emergency Wage Subsidy (CEWS) means the inflow of cash, receivables, or other consideration arising in the course of its ordinary activities in Canada in a particular period. ... Generally, we would expect extraordinary items to meet all three of the following characteristics: a) Not be expected to occur regularly or frequently within several years Grants or other government assistance that an entity is eligible to receive on a regular or reoccurring basis would not meet this criteria. b) Not typical of the normal activities or risks inherent in the normal operations of the entity Consideration should be given to the nature of the services or products offered by an entity and the normal environment in which it operates. c) Primarily out of the control of owners or management Consideration should be given to the extent that inflows are influenced by the decision of owners or management. ...

For purposes of the CEWS, qualifying revenue of an eligible entity for a prior reference period or a current reference period, means the inflow of cash, receivables, or other consideration arising in the course of the ordinary activities of the eligible entity in Canada in a particular period, subject to certain inclusions and exclusions. ... Whether business interruption insurance proceeds are included in an eligible entity’s qualifying revenue is a question of fact that can only be determined after a review of the particular terms of the insurance coverage and consideration of other relevant facts and surrounding circumstances. ... 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. ...

Corporations B and C wish to amalgamate but are unable to do so because of various financial, legal and other considerations. 4.      ... As consideration for corporation A issuing its common shares to the public on the above amalgamation, corporation B issues additional common shares to corporation A. 8.      ... As consideration for corporation A issuing shares to the public, corporation A issues additional shares to corporation A. ...

.- `cumulative eligible capital' of a taxpayer at any time in respect of a business means the amount by which the aggregate of     (i)  1/2 of the aggregate of the eligible capital expenditures in respect of the business made or incurred by the taxpayer before that time, and     (ii) all amounts included by virtue of subsection (1) in computing the taxpayer's income from the business for a taxation year ending prior to that time,      exceeds the aggregate of     (iii)all amounts each of which is an amount in respect of any taxation year of the taxpayer ending before that time, equal to the amount deducted under paragraph 20(1)(b) in computing the taxpayer's income for that year from the business, and     (iv) the aggregate of all amounts each of which is 1/2 of the amount, if any, by which     (A)  an amount that, as a result of a transaction occurring after 1971, became payable to the taxpayer before that time in respect of a business carried on or formerly carried on by him where the consideration given by the taxpayer therefor was such that, if any payment had been made by the taxpayer after 1971 for that consideration, the payment would have been an eligible capital expenditure of the taxpayer in respect of the business,      exceeds     (B)  any outlays and expenses to the extent that they were made or incurred by him for the purpose of giving that consideration; and" It is therefore our view that, by virtue of subparagraph 14(5)(a)(iv) of the Act as it read at that time, the inclusion rate would be 1/2 or 50%, in respect of a sale of goodwill by a corporation, during a fiscal year which commenced February 1, 1988 and ended January 31, 1989. ...

Secondly, you enquired as to whether the application of subsection 69(11) to the situation described herein is precluded because the fair market value of the shares of X Co issued as consideration for the property as equal to the fair market value of the property at the time of the transfer of the property to X Co.  In our view, the application of subsection 69(11) to a transfer is not precluded because the transfer is for fair market value consideration. Subsection 69(11) may apply where the proceeds of disposition of, as opposed to the value of the consideration for, the transferred property is less than the fair market value of such property. ...

We understand that the deceased taxpayer sold her entire farming operation to her daughter and as part of the sale, cattle and feed inventory was transferred to the daughter in consideration of a promissory note in the amount of $XXXXXXXXXX. ... On the contrary both the Bill of Sale and the Purchase and Sale Agreement refer to the promissory note as the consideration given for the transfer of the inventory. ... As the promissory note was received as consideration for the inventory transferred and accepted as absolute payment, there is no amount owing on the sale of the cattle and feed inventory. ...

Pursuant to proposed paragraphs 80(2)(g) and 80(2)(g.1) of the Act: (g) where a corporation issues a share (other than an excluded security) to a person as consideration for the settlement of a debt issued by the corporation and payable to the person, the amount paid in satisfaction of the debt because of the issue of the share shall be deemed to be equal to the fair market value of the share at the time it was issued; (g.1)where a debt issued by a corporation and payable to a person is settled at any time, the amount, if any, that can reasonably be considered to be the increase, as a consequence of the settlement of the debt, in the fair market value of shares of the capital stock of the corporation owned by the person (other than any shares acquired by the person as consideration for the settlement of the debt) shall be deemed to be an amount paid at that time in satisfaction of the debt; Under these proposed provisions a corporate debtor is considered to have paid an amount in satisfaction of a debt equal to the fair market value of a share, where that share is issued by the debtor as consideration for the settlement of the debt. Pursuant to proposed paragraph 80(2)(g.1) of the Act, a corporate debtor is considered to have paid an amount equal to the increase in value of the shares of the capital stock of the debtor that are owned by the creditor (other than those shares issued as consideration for the settlement of the debt) to the extent that the increase in value is as a consequence of the settlement of the debt. ...

No valuable consideration- no benefit of any kind- to the donor or to anyone designated by the donor may result from the payment. ... Since the contributor has received consideration in return for his contribution, no gift has been made. ... A donation of property to a registered charity is not a gift for the purposes of the Act if there is consideration of any kind being received in return. ...

The term "pension" means periodic payments made in consideration of past services. ... Article XI(3) of the treaty defines the term "pension" as "periodic payments made in consideration of past services" as opposed to referring only to "periodic payments". We could not simply ignore the words "made in consideration of past services". ...