Search - consideration

Case-by-case consideration would be given to a request for relief in respect of such foreign subsidiaries, just as it would be given in respect of subsidiaries located in any other country. ...

Les facteurs à prendre en considération pour faire cette détermination sont indiqués au paragraphe 3 du Bulletin d’interprétation IT-206R. ...

" Netherlands "The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including motion picture films and works on film, videotape or other means of reproduction for use in connection with television, any patent, trade mark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment or for information concerning industrial, commercial or scientific experience. ... The elected amount was $190,000 and the consideration received by X was preferred shares of Holdco having a FMV of $375,000, an ACB of $190,000 and a PUC of $100. 8. ... Z receives only share consideration from Opco in order to avoid taxation under section 84.1. ...

(2) Whether a corporate beneficiary receiving an interest in a life insurance policy from a trust as payment of a dividend in kind received by the trust should be considered as having given a consideration for the interest in the life insurance policy? ... To the extent that it is determined that at the time of disposition of the life insurance policy, the beneficiary’s income interest under the trust would include the right to enforce payment of an amount by the trust equal to the FMV of the life insurance policy, it could be argued that the consideration given by the beneficiary to the trust for the interest is equal to the FMV of that life insurance policy. ... The consideration given by the beneficiary to the trust for purposes of clause 148(7)(a)(ii)(B) corresponds to the amount of the debt being settled. ...

In any particular case, it is a question of fact as to whether the specified individual was actively engaged on a regular, continuous and substantial basis in the business, which necessitates the consideration of various factors, including, among other things, the individual’s specific involvement and the nature of the business. ... In particular, the “excluded shares” and “reasonable return” exceptions should also be taken into consideration. ... Par exemple, les exclusions pour « actions exclues » et pour « rendement raisonnable » devraient également être prises en considération. ...

These assessments crystallize the taxpayer's obligation to make payment (or provide appropriate security), raise the issues, and define the issues for consideration by Appeals or Competent Authority. ... " It would be difficult to develop and administer transfer pricing agreements for the assessment of Part XIII tax that takes into consideration the varying rules in Canada's treaties. ...

Thereafter, the individual decides to sell his interests in the trust to a third party for a consideration of $1,000,000. ... Even if the transferor and the transferee are dealing at arm's length, CRA could reallocate the consideration between the different types of interest in accordance with section 68 of the ITA if it determines that the value that was attributed to the two types of interests is unreasonable. ...

Immédiatement après l'échange d'actions décrit ci-dessus, Fiducie FX souscrira à 100 nouvelles actions ordinaires du capital-actions de XCO, pour une considération de 100 $. 7. ... Immediately after the share exchange described above, FX Trust will subscribe to 100 new common shares of the capital stock of XCO, for a consideration of $100. 7. ...

The CCRA's response It should first be noted that the text of this question only summarizes very briefly a hypothetical situation (the "Given Situation") and, among other things, does not provide information about the consideration received by the selling shareholders and the use of Opco's assets after the transaction is completed. ... It is also difficult for us to take a definitive position on the potential application of section 84.1 in the Given Situation because the text of this question only summarizes very briefly the Given Situation and, among other things, does not provide any information about the consideration the selling shareholders would receive, or if the selling shareholders are not dealing at arm's length or are deemed not to be dealing at arm's length with the purchaser. ...

The value of the consideration given by the QBIC for the the shares is the loan receivable from its shareholder. ... (i.e. the value of the QBIC's consideration to acquire the shares). ...