Search - consideration

This issue is still under active consideration by the CRA. … [C]rypto-assets, by their very nature, are more difficult to track than traditional assets. ...

CRA stated: [T]he CRA would not generally apply subsection 15(1) solely as a result of the granting of a guarantee where the CRA is of the view that the individual pays the individual’s corporation a reasonable guarantee fee as consideration for the individual’s corporation granting a mortgage guarantee of a personal loan of the individual. ...

…[T]aking into consideration the foreign law under which the Partnership was formed, the provisions of the partnership agreement and the terms and conditions of the loan agreement between the Partnership and the U.S. lender, the CRA came to the conclusion that the partners of the Partnership were considered to be the payers of the interest on the Loan. ...

Among the rights that would require consideration in determining the differences, would be the right to the issued and paid-up capital respecting a share of one class as compared to that for another class. ...

CRA stated: In broad terms, a deemed trust established under those provisions ceases to apply to property of a tax debtor when the tax debtor disposes of the property in the normal course of business for FMV consideration to an arm's length bona fide purchaser. ...

10 October 2014 APFF Roundtable, 2014-0538261C6 F- Disposition of capital interest/personal trust-- summary under Cost Amount Summary Under Tax Topics- Income Tax Act- 101-110- Section 108- Subsection 108(1)- Cost Amount note issuance is not trust property distribution to a beneficiary In order to settle the capital interest in a discretionary family trust of a beneficiary who is related to the trustees, that beneficiary agrees to renounce his interest in consideration for $200,000 paid by the trust as to $50,000 in cash and as to $150,000 by the issuance of a promissory note due by the trust in 5 years' time and bearing interest at 5%. ...

10 October 2014 APFF Roundtable, 2014-0538261C6 F- Disposition of capital interest/personal trust-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) non-deductible interest on note issued to beneficiary In order to settle the capital interest in a discretionary family trust of a beneficiary who is related to the trustees, that beneficiary agrees to renounce his interest in consideration for $200,000 paid as to $50,000 in cash and as to $150,000 by the issuance of a promissory note due in 5 years' time and bearing interest at 5%. ...

[W]e have not had the opportunity to give full consideration to whether the above position should apply for purposes of [s. 104(4)(a).] ...

After noting that Chan indicated that a distribution under s. 107(2) is an allotment made in accordance with the beneficiary's interest and not made for consideration, CRA stated: Under the law of equity, fiduciary duties are imposed on a trustee and are enforceable by the beneficiaries of a trust. ...

Consideration should also be given to any factors which could have an effect on the relative value of any of the units in the building. ...