Search - consideration

Step B: A absolutely assigns the policy to B for no consideration. A would not incur any additional policy gain because the proceeds of disposition would be deemed to be zero under subsection 148(7). ... CRA Response B: Where A assigns the policy to B for no consideration such that subsection 148(7) of the Act applies to the transfer, the legislation provides that A will be considered to have received proceeds of disposition on the transfer in an amount equal to the "value" of A's interest in the policy at the time of the transfer. ... B absolutely assigns the policy to A for no consideration. After the policy loan, the amount that would be payable on surrender of the policy would be zero. ...

The consideration received by the transferor consists solely of shares of the capital stock of the transferee corporation. Would the CRA invalidate the price adjustment clause and apply subsection 15(1) of the ITA, if the persons believe that they do not have to file an amended election and pay the penalty provided in subsection 85(8) of the ITA, because the "agreed amounts" and the "description of property disposed of" remained unchanged, and the parties made the corrections required by the CRA concerning the amount of the fair market value of the transferred property and the consideration received by the transferor? ... An acceptable price adjustment clause has to adjust the price of the property transferred and the consideration received, not the quantity of the property transferred. ...

Pursuant to paragraph (b) of both the current and proposed definitions of "flow-through share," the amount of resource expenses that may be renounced under the agreement cannot exceed the amount of consideration received by the corporation for the flow-through share or the right to acquire the flow-through share, as the case may be. ...

17 May 2012 Roundtable, 2012-0444131C6- Policy Initiatives Principal Issues: Update on policy initiatives under consideration by International and Large Business Directorate's International Tax Division Position: Comments provided. ...

The initial folios workload was prioritized for action based on considerations that included: feedback received through internal and external consultations to identify the public need for guidance in each technical subject area; and the availability of resources to prepare the required updates. ...

Position: This question was sent to the Department of Finance for their consideration. ...

Similarly, while the CRA does not apply subsection 75(2) to a genuine loan of cash, including a conditional sales agreement for the sale of property, solely by reason of the fact that the outstanding debt will be repaid, subsection 75(2) of the Act does apply if a capital beneficiary of a trust transfers property to that trust, regardless of whether or not the capital beneficiary receives fair market value consideration. 2006 STEP Round Table Q4. ... Note that, while the CRA does not apply subsection 75(2) to a genuine loan of cash, including a conditional sales agreement for the sale of property, solely by reason of the fact that the outstanding debt will be repaid, subsection 75(2) of the Act does apply if a capital beneficiary of a trust transfers property to that trust, regardless of whether or not the capital beneficiary receives fair market value consideration. ...

The payment is consideration for the shares. The issue of shares is not a transfer since the corporation has not divested itself of its property: the shares were never owned by the corporation. ... The corporation is usually enriched, not impoverished, when shares are issued for consideration; when a corporation issues a stock dividend it is neither enriched nor impoverished. ...

29 November 2011 Roundtable, 2011-0426361C6 F- Price adjustment clause and redemption of shares CRA Tags 84(3) Principal Issues: In the course of an estate freeze, preferred shares are issued to a taxpayer in consideration for common shares. ... Pursuant to that price adjustment clause, the redemption value of the preferred shares would be adjusted to reflect the fair market value of the consideration if the amount considered to be the fair market value is changed. ...

Therefore, in the CRA’s view, the plan must be: (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. ... More recently the CRA has expressed the view in Technical Interpretation 2014-0521301E5 (dated June 25, 2014) that: …. a cost-plus plan under which the administrator agrees to reimburse the sole employee-shareholder, his or her spouse, and members of his or her household for actual medical and hospital expenses and receives, as consideration, an amount equal to the amount reimbursed plus an administrative fee, does not qualify as a PHSP since it does not contain the necessary elements of insurance. ...