Search - consideration

X is giving consideration to making a gift of his plan to a registered public foundation in order to create a permanent endowment fund to benefit a cause of his choice in the education sector. ... The tax consequences of a transaction must be established taking into consideration all the relevant facts. ...

The calculation of the amount or value of the benefit is usually based on the fair market rent for the property minus any consideration paid to the corporation by the shareholder for the use of the property. ... Any consideration paid to the corporation by the shareholder for the use of the property is then subtracted from the imputed rent. ...

In general, for purposes of determining whether an amount would have been an excluded amount in respect of the deceased spouse or common-law partner (the “Spouse”) of a specified individual under subparagraph 120.4(1.1)(c)(ii) if the amount had been included in the Spouse’s income, consideration should be given to all of such Spouse’s relevant facts and circumstances in the applicable taxation year, including in the case of determining whether an amount is an excluded amount because it is income from excluded shares, any shares of a corporation owned by such Spouse. ... Whether the amount of the Dividend would have been income from excluded shares of A should take into consideration the following: (1) A owned shares of Canco throughout A’s last taxation year before death; (2) such shares met the requirements for being excluded shares under subsection 120.4(1) during that period; and (3) we will consider the amount of the Dividend that was notionally included in computing A’s income for purposes of subparagraph 120.4(1.1)(c)(ii) to be income from such shares. ...

Le résultat est qu’aux fins du calcul du « plafond annuel des gains » du bénéficiaire, le montant calculé à l’élément A prend en considération le gain en capital imposable attribué par la fiducie par suite d’une attribution selon le paragraphe 104(21.2) L.I.R. afin de permettre au bénéficiaire (s’il est un particulier autre qu’une fiducie) de réclamer la déduction pour gains en capital selon le paragraphe 110.6(2.1) L.I.R. ... En effet, l’attribution effectuée selon le paragraphe 104(21.2) L.I.R. par Fiducie 1 doit être prise en considération afin de déterminer les gains en capital imposables admissibles de Fiducie 2 et de Fiducie 3. ...

X disposes of his OPCO common shares in consideration for preferred shares of OPCO. ... X then disposes of 15 % of his OPCO preferred shares in favour of EMPLOYEECO, in consideration for a promissory note. ... X will implement a freeze by disposing of his common shares in consideration for redeemable preferred shares with a FMV of $2,000,000. 2. ...

(iii) Subco transfers its A division to Newco in consideration for preferred shares in Newco. ... The first issue of Newco shares will take place in stage (ii), that is these shares will be issued to Mco in consideration of the acquisition of shares in Subco. ... However that case dealt with standby fees, which do not represent a consideration for the use of borrowed money. ...

Neuman’s wife subscribed for class “F” shares of the corporation in exchange for a consideration of $99. ... In consideration, it would receive shares of Opco Z of the same type and having the same value. ... Department of Finance reply The same considerations were raised in question 41. ...

For example, a taxpayer's submission must contain the rationale and support for the proposed transfer pricing methodology and the taxpayer must be open to the consideration of alternative methodologies and/or transactions. ...

This determination must take into consideration all the applicable circumstances including the terms and conditions of the estate. ...

Where the trust has accrued and reported interest on a debt obligation and has at any particular time disposed of the obligation for consideration equal to its fair market value at the time of disposition, the trust may, by virtue of subsection 20(21) of the Act, deduct in computing income for the year of disposition the over accrued amount; that is the amount, if any, by which the aggregate of the amounts of interest on that debt obligation that were included in the trust's income for the year of disposition and all previous years exceeds the total interest actually received thereon. ...