Search - consideration

IT-220R2 "Capital Cost Allowance- Proceeds of Disposition of Depreciable Property"-- summary under Section 68 Summary Under Tax Topics- Income Tax Act- Section 68 Detailed discussion under heading "Combined Consideration". ...

.- Q.32-- summary under Subsection 85(1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1) A deferred tax liability does not constitute non-share consideration. ...

Regarding s. 231(1), CRA stated: In general, a supplier may claim a deduction from net tax for a bad debt where the following conditions are met: the supplier made a taxable supply (other than a zero-rated supply) for consideration to a recipient with whom it was dealing at arm's length; it is established that all or part of the total of the consideration and tax payable in respect of the supply has become a bad debt and the supplier writes off the bad debt in its books of account; the supplier included the tax collectible in respect of the supply in determining its net tax reported in the return for the reporting period in which the tax became collectible and remitted all net tax remittable, if any, as reported in that return; and the supplier claims the deduction in a return filed within the four year time limit set out in subsection 231(4). ...

The Holdco subsidiary (Subco) transfers a property, with an FMV of $925,000 to Holdco in consideration for Class B shares, as a result of which the PUC of the Class B shares of the individual is increased to $750,000. Transactions – Scenario 2 (use of s. 40(3.6) and soft ACB to increase PUC) Canco redeems an individual’s preferred shares (which had an ACB of $850,000 due to a previous capital gains crystallization transaction) for $850,000, triggering a deemed dividend of $849,999 and an equivalent capital loss which is added to the ACB of the common shares under s. 40(3.6) The individual’s common shares are transferred to Holdco in consideration for preferred shares with an ACB, PUC and redemption value of $850,000, and for nominal value common shares. ...

.- Q.45-- summary under Subsection 84(3) Summary Under Tax Topics- Income Tax Act- Section 84- Subsection 84(3) The calculation of the amount of the dividend arising on a purchase for cancellation will include the value of any type of consideration given for the shares including a promise to pay. ...

.- Q.4-- summary under Subsection 103(1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 103- Subsection 103(1) One of the considerations in determining the reasonableness of profit allocation is any personal use by a partner of partnership property. ...

14 May 1999 Headquarters Letter HQR 0001500-- summary under Section 139 Summary Under Tax Topics- Excise Tax Act- Section 139 Fees received for distributed mutual fund units were consideration for a single supply notwithstanding that customer services also were provided. ...

.- Q.23-- summary under Subsection 66(12.66) Summary Under Tax Topics- Income Tax Act- Section 66- Subsection 66(12.66) Description of trust account procedure for meeting the requirement that the consideration be paid before the end of the year. ...

The payment of property taxes by a tenant, pursuant to the terms of a lease agreement, constitutes consideration for the lease of property where the landlord has a joint liability to pay such property taxes. ...

4 February 1992 Memorandum (Tax Window, No. 16, p. 21, ¶1730)-- summary under Other Summary Under Tax Topics- General Concepts- Fair Market Value- Other Appraisals of art collections should be made on a piece by piece basis with little or no consideration given to premiums or discounts. ...