Search - consideration

X) giving that employee the right to acquire common shares of the capital stock of Opco for a consideration of $1. ...

This is the previous table which is amended to take into consideration the effect of section 257 of the ITA. 2006 2007 2008 2009 According to scenario 1: Element A of the definition of annual gains limit 0 0 0 150,000 Element B of the definition of annual gains limit 0 100,000 0 0 Annual gains limit (A-B) 0 nil 0 150,000 Cumulative gains limit 0 nil nil 150,000 According to scenario 2: NO MODIFICATION Element A of the definition of annual gains limit 0 0 0 150,000 Element B of the definition of annual gains limit 0 0 0 0 Annual gains limit (A-B) 0 0 0 150,000 Cumulative gains limit 0 0 0 150,000 François Bordeleau (613) 957-2082 October 9, 2009 2009-033024 ...

By taking the aforementioned into consideration and by assuming that the other conditions stated in Interpretation Bulletin IT-148R3 are complied with, can the CRA indicate to us if the reduction in the rate of absenteeism or the increase in the productivity of its employees brought about by the employer, is sufficient to determine that there would be no taxable benefit imposed on the employees benefiting from a payment or reimbursement by the employer of the club dues or membership fees? ...

CRA Response a) Assuming that the foreign entity is a trust for Canadian tax purposes and that this foreign entity's beneficial interests (hereafter "capital interest") were acquired for consideration, there might be a reduction in the adjusted cost base (ACB) of the capital interest in accordance with subparagraph 53(2)(h)(i.1) of the ITA where an amount has become payable to the beneficiary in respect of his interest and where this amount is not the proceeds of disposition of the interest or part thereof, and this, to the extent that the amount or part thereof, is not subject to one of the exceptions provided in this subparagraph. ...

In Cloutier, the Court mentions the following on pages 225 and 226: To begin with, I do not think it is appropriate in interpreting social legislation like the Unemployment Insurance Act to adopt an approach similar to that required to give effect to fiscal legislation, the reason being that the same considerations do not apply in giving effect to these two types of legislation. ...

These elements, which are listed in paragraph 3 of IT-339R2, are the following: (a) an undertaking by one person, (b) to indemnify another person, (c) for an agreed consideration, (d) from a loss or liability in respect of an event, (e) the happening of which is uncertain. ...

In order to clarify the CRA's position, and taking into consideration the new facts outlined above: (i) Will subsection 75(2) ITA apply to the income, losses, taxable capital gains and deductible capital losses derived by Trust X from Corporation Y's shares so as to allocate these amounts to Corporation Y? ...

Également, la présomption de propriété contenue à la fin paragraphe 80.01(2) doit être prise en considération dans la détermination de ce moment. ...

Paragraph (b) of the definition of CCPC provides notably for the situation where a corporation would be controlled by a particular person, if each share of the capital stock of the corporation that is owned by a non-resident person were owned by the particular person. a) De Jure Control and Option Holding For the purposes of this definition, we must also take into consideration the options held by a person because of paragraph 251(5)(b) I.T.A. ...

A in Year 2 would not constitute an “excluded amount” and would, absent any other consideration, be considered split income of Mr. ...