Search - consideration

During the second review, you will have the opportunity to provide additional information for the CRA’s consideration. ...

Thus, in view of the foregoing and taking into consideration the comments that follow, a loan received in the hypothetical circumstances of your example would probably come within the exception in subparagraph 15(2)(a)(ii) of the Act. ...

We would expect that any actuarial valuation would take into consideration amounts to be paid out of the RPP for management and administration cost, regardless of to whom those payments are made or how they are to be effected.  ...

With respect to the latter we would point out that this is true only to the extent, as set out in paragraph 21 of Interpretation Bulletin IT-5ll, that the consideration received for the transfer by one spouse to the other is also valued at fair market value and the other condition in subparagraphs (b) and (c) are met. ...

A determination of the reasonableness of the amount of remuneration paid to any particular shareholder-employee requires consideration of the duties performed by the individual, as well as the time spent in carrying out those duties.  ...

Pursuant to subparagraph 18(9)(a)(i) of the Act no deduction may be made in the initial year in respect of the remaining portion of the fee which may be viewed as consideration for services to be rendered after the end of that year.  ...

The particular aspect of the paper with which you are concerned, and which is described on page 18:22 of the 1988 Conference Report, pertains to the transfer of a property by a (parent) corporation to a wholly-owned subsidiary (the "controlled corporation ") in consideration for shares of the controlled corporation.  ...

It should also be noted that our previous memorandum to the District Office did not rely on subsection 69(1) of the Act, the proceeds are equal to the fair market value of the consideration taken back which was the common shares of 24(1) We are returning herewith the orange appeal file and the 1984 T1 returns for each of the 24(1) included with your earlier memorandum. ...

The fact that a loan is received by an officer or employee or his spouse or by an individual who is to become an officer or employee or his spouse, from a party other than his employer is not necessarily indicative that such loan has not been received by virtue of an office or employment, the Department will take into consideration any involvement or assistance by his employer in obtaining the loan, including (a)     involvement in negotiation of the loan. ...

Therefore, I am sending a copy of our correspondence to the Honourable Chrystia Freeland, Minister of Finance, for her consideration. ...