Search - consideration

Subsection 86(2) of the Act does not apply if the fair market value of the preferred shares received as consideration for the disposition of the common shares, referred to as the "old shares" for purposes of section 86, is equal to the fair market value of the new shares.  ...

In the case of a deemed disposition, ownership of property is not handed over to another person for consideration.  ...

Royalties are defined in paragraph 4 of Article XII of the treaty to include payments of any kind received as consideration for the use of, or the right to use any patent. ...

In particular, the following steps would occur: (i) Bidco would be incorporated under the laws of Ontario; (ii) Aco and Bco would each subscribe for more than 10% of the shares of the same class of voting shares of Bidco, Cco would subscribe for all the shares of another class of voting shares of Bidco and Management would subscribe for all the shares of another class of voting shares of Bidco; (iii) Bidco would borrow funds from financial institutions (including Aco and Bco); (iv) Bidco would make a takeover bid (the "Bid") for all of the outstanding shares of Xco and would pay for such shares with cash consideration. ...

This determination would require a review of all relevant connecting factors and consideration as to how much weight should be given to each factor. ...

Upon application by the non-resident for a certificate as described above, paragraph 1 of Article VI of the Treaty would be taken into consideration by the Department and a payment of 15% of the taxable portion of the income arising from the disposition of the policy (i.e. the estimated tax) or acceptable security thereon may be accepted. ...

Un «paiement» à une université dans le cadre d'un contrat de recherche peut-il être effectué sous forme de transfert de biens sans considération monétaire? ...

The quantity and quality of his efforts must also be taken into consideration in determining his share in the income of the business. ...

In the fact situation, the escrowed shares were issued for nominal consideration and were held in escrow pursuant to requirements of an arm's length governing body (the Vancouver Stock Exchange). ...

This determination would require a review of all relevant connecting factors and consideration as to how much weight should be given to each factor. ...