Search - consideration

., c’est la moins élevée des sommes déterminées à l’égard de la société pour l'année selon les alinéas 125(1)a) à c) L.I.R. qui est prise en considération. ...

However, we want to undertake a thorough study, by taking into consideration, among others, the extent of the problem before determining which approach to adopt in such a situation. ...

We recognize that the Act does not specifically define the cost of a life insurance policy and we have brought this to the attention of the Department of Finance for their consideration. ...

Taking this guidance into consideration, the CRA is of the view that, in applying the substantial requirement test: The size of the trade or business in the U.S. need not be "as large as" the income-generating activity in Canada; but it must be more than "a very small percentage" of the size of that activity. ...

When the gift is made without consideration, it is deemed to be made at the fair market value of the property which can result in a capital gain or capital loss and in the case of depreciable property the gift could even give rise to recaptured depreciation. ...

On the other hand, in a technical interpretation given in 2004 (2004-009256), for example, the CRA was of the opinion that no disposition, for the purposes of the application of section 85 of the ITA, would occur in a situation where a sole shareholder of a private corporation would dispose of all of the 100 common shares that he owns in favour of the issuing corporation in consideration for 100 new common shares and preferred shares having a redemption price of $500,000. ...

A to have disposed of the policy for proceeds equal to the greatest of the FMV of the consideration given, the ACB of the policy and the CSV of the policy at the time of transfer. ...

This is not intended to be an exhaustive list as each case may warrant different considerations based on its particular fact situation and be settled differently. c) The use of foreign trusts to hold capital and earn income is a concern for many countries around the world. ...

Finance's Response We agree with the CRA that an unfunded SERP that provides unreasonable benefits should be considered to be an SDA, and that the determination of "reasonableness" in this context can require the consideration of any number of factors the relevance of which will depend on the particular circumstances. ...

In a technical interpretation issued a while ago, the CRA mentioned that this question was under consideration. ...