Search - consideration

They would also be redeemable and retractable for an amount equal to the consideration for which the shares are issued. ... For example, the CRA is of the opinion that if, when the loan is made by Corporation A, Corporation B is unable to repay the loan and/or provide reasonable security for repayment, Corporation A would then have transferred property (cash) without having received sufficient consideration. ...

As a result, the condition set out in subparagraph 70(6)(b)(ii) would not be met. (3) No proceeds of disposition would be deemed received for the purposes of subsection 106(2) when the usufructuary validly surrenders, without consideration and without directing in any manner who is entitled to benefit therefrom, his/her income interest in the deemed trust. ... Subsections 107(2.1) and (4) would apply to this distribution and it could be possible for the personal trust to claim the principal residence exemption under paragraph 40(2)(b), provided that the conditions for the property to qualify a “principal residence” as defined in section 54 are all met. (4) By effect of subsection 70(5) or paragraph 69(1)(b), as the case may be, the bare owner would be deemed to have received a consideration equal to the FMV of his/her capital interest in the deemed trust as a result of the deemed disposition at death or of the assignment of his/her right in favour of the usufructuary, as the case may be. ...

Also if an issue is one that appears to be of concern to a number of taxpayers consideration will be given to communicating the Department’s position in our Technical Newsletters. ... Had the purchaser not assumed the contingent liabilities, the amount of cash or other consideration that it would have had to pay would have increased accordingly. ... Consequently, the application of the cost plus method requires careful consideration of the relative efficiency of the service providers being compared. 72. ...

The payment of a bill or invoice of the deemed resident trust by a beneficiary for no consideration would constitute a "contribution" as defined in proposed subsection 94(1). ... In situations where a trust governed by an RRSP acquires property for consideration that is greater than the fair market value of the property at time of acquisition, the difference between the fair market value and the consideration is included in the annuitant's income under subsection 146(9). ... If unintended tax consequences are caused by the application of subsection 256(9), consideration should be given to electing out of subsection 256(9). ...

Consideration will be given to allow subsection 153(1.1) reductions for more than one year, if the original circumstances supporting the reduction continues in future years. ... Department's Position (a)     Whether bona fide arrangements are made for the repayment of a housing loan within a reasonable period of time at the time the loan is made is a question of fact which can only be determined upon consideration of all the circumstances of a particular situation.  ...

With respect to the capital payment, the capital gain or loss should be calculated by taking into consideration the above-mentioned position. ...

As part of its review of a particular case, the CRA will give consideration to the existence of a court order or agreement; however, the only legal authority for determining benefit eligibility is the ITA. ...

Response 3: We are still of the view that when a holder of an exchangeable debenture exercises the right to exchange the debenture for the target shares, the holder would dispose of the debenture for proceeds equal to the fair market value of the consideration received, i.e. the fair market value of the target shares. ...

X and their FMV, for example, without taking into consideration, amongst other things, the CRA's valuation principles, practices and policies in Information Circular 89-3, while a prudent and conscientious person exercising due diligence would have done it. ...

The individual received an amount of $100,000 cash as consideration for the disposition (being the ACB of the shares of Corporation B) and shares of PORTCO (for the difference between $100,000 and the FMV of the shares of Corporation B at the time of the transfer). ...