Search - consideration

Additionally, consideration is being given to a number of risk factors, such as: Audit History; Industry Sector Issues; Unusual and/or complex transactions; Corporate Structure; Major acquisitions and disposals; International transactions; Corporate Governance; Participation in aggressive tax planning; and Openness and transparency. ... We are also giving consideration to creating an ALBC Website to provide taxpayers with information about the approach. ...

7 October 2016 APFF Financial Strategies and Instruments Roundtable Q. 1, 2016-0651771C6 F- Critical Illness Insurance Unedited CRA Tags 15(1) Principales Questions: Whether subsection 15(1) could apply to the transfer (without consideration) by a corporation of its critical illness insurance policy to its sole shareholder? ... Raisons: No consideration paid by the shareholder. Table ronde sur la fiscalité des stratégies financières et des instruments financiers du 7 octobre 2016- APFF Congrès 2016 Question 1 Transfert d’une police d’assurance maladies graves par une société par actions à un actionnaire Une société par actions exploitante (« Opco ») a souscrit, il y a plusieurs années, à une police d’assurance maladies graves à l’égard de son unique actionnaire, qui participe très activement aux opérations courantes de la société. ...

Accordingly, there are three options available to the estate, namely: The estate could make an assignment into bankruptcy, in which case the trustee in bankruptcy would make the decision as to whether an objection or appeal should be pursued; The executor could personally fund the services of an accountant and in the event that there is a decrease in tax payable, consideration could be given to permitting the fees to be paid out of the assets of the estate; or The executor could use estate assets to fund the services of an accountant, but would do so at the risk of being held liable under subsection 159(3). There are positive and negative aspects to each of these options which will require consideration from the legal representative. ...

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 consideration." ... As stated by the CRA at the CLHIA Roundtable in May 2009, we recognize that the Act does not specifically define the cost of an interest in a life insurance policy and we have brought this to the attention of the Department of Finance for their consideration. ...

Headquarters will generally in turn refer the matter to the GAAR Committee for consideration. ... Thus taxpayers should be assured that when the application of the GAAR is considered, all their arguments will have received careful consideration. ...

Headquarters will generally in turn refer the matter to the GAAR Committee for consideration. ... Thus taxpayers should be assured that when the application of the GAAR is considered, all their arguments will have received careful consideration. ...

Toutefois, une interprétation subséquente 2 vient remettre en doute cette interprétation et ne semble pas avoir pris en considération l'analyse approfondie de la position antérieure. ... However, a subsequent interpretation 4 questions this interpretation and it seems that the thorough analysis of the former position was not taken into consideration. ...

The discounting takes into consideration the age of the shareholder and his life expectancy according to Statistics Canada. ... For these reasons, in the given situation, we are of the opinion that it would not be appropriate to take into consideration the RDTOH in the determination of the FMV of the shares subject to the freeze. ...

Department's Position The new reporting requirements set out in CICA Handbook Section 3860 are rather extensive and as suggested may have income tax implications that require consideration from a tax policy perspective. To the extent that you encounter such potential concerns they should be submitted to the Department of Finance for consideration. ...

Il nous semble également que des options d'achat d'actions peuvent ne pas avoir été émises à des employés nécessairement en considération de services rendus, dans tous les cas. ... We also feel that stock options may not necessarily in all cases have been granted to employees in consideration for services rendered. ...