Search - consideration

Where such certificates are not required, the date of physical completion must be determined on the facts of each case, taking into consideration factors which suggest that the contract is "completed", such as acceptance of the project by the owner except for minor adjustments for incompleted work, or actual occupancy by the owner. ...

If the property is so contributed and each partner receives no consideration other than the partner's interest in the new partnership, the cost of that interest and the proceeds of disposition of the property contributed will be equal to the aggregate of the amounts determined under subsection 98(3) and no capital gain will result. ...

However, the reasonable basis should also take into consideration the personal use, if any, of the work space if it is one described in 2(a) above. ...

Although the assumption of a debt or obligation of a taxpayer by a third party may not constitute payment by the taxpayer in a strict sense, the rules described in 1 above are not applied if the third party receives consideration from the taxpayer at least equivalent to the principal amount of the debt or obligation assumed. 14. ...

In making such a determination, consideration will be given to the nature of the business and the individual's involvement in the day-to-day operation of that business. ...

A sale of a right or thing for good and valuable consideration does not come within the meaning of the phrase "transferred or distributed" as used in subsection 70(3). ...

Please refer to the current issue of Information Circular 71-17 with respect to requests for competent authority consideration. 11. ...

(h) Sale of Property Where a taxpayer sells a property at a time when a deductible outlay or expense remains unpaid, and the purchaser assumes the obligation to pay the unpaid amount as full or partial consideration for the purchase, section 78 will not be applied to the taxpayer if the purchaser pays the unpaid amount before the date on which subsection 78(1) becomes operative. ...

Any amount paid or credited to a non-resident in consideration for the non-resident's agreeing to guarantee, in whole or in part, the principal amount of an obligation of a resident of Canada is deemed to be a payment of interest on that obligation. When a non-resident has entered into an agreement to lend money or make money available to a resident of Canada, any amount paid or credited to the non-resident in consideration for such agreement is deemed to be a payment of interest provided that, on the date such agreement was entered into, Part XIII tax would have applied to interest payable on any obligation issued pursuant to that agreement- 214(15). ... The dividend that is deemed to be paid to the non-resident is equal to the amount by which the fair market value of consideration (other than shares of the purchaser corporation) received exceeds the paid-up capital of the shares transferred. ...

Memorandum of Understanding TN-34 Computer software royalties TN-23 Concessions capital cost allowance IT-477(C) Condominiums capital cost allowance IT-304R2 direct ownership of units in Quebec, capital cost allowance IT-304R2 ownership IT-437R Congregation residence deduction IT-141R(C) Consideration disposition of property, without IT-460 Construction industries construction, defined IT-411R Containers capital cost allowance IT-472(SR) deposits, special reserves IT-154R Contests prizes, taxation IT-213R Contractors income computation IT-92R2 movable equipment, capital cost allowance IT-306R2; IT-469R Contracts annuity – see Annuity contracts- novation, taxation IT-334R2- payments for non-performance IT-467R2- receipts for non-performance, taxation of amounts IT-365R2- service, fees received for, taxation IT-334R2- types, tax implications IT-92R2 Control in fact impact of recent jurisprudence TN-32 Control of corporation income trust- change in trustees TN-38 Controlled corporations – see also Private corporations, Canadian controlled basic rules IT-64R4(C) change in control- investment tax credit IT-151R5(C)- loss utilization restrictions IT-302R3- related to change in executors, etc. of estates IT-302R3- scientific research and experimental development IT-151R5(C) control deemed not to have been acquired IT-302R3 control defined IT-64R4(C); IT-302R3 loss on disposition of property to IT-291R3 Convention expenses deduction from income IT-131R2 Convertible debt obligation redemption or cancellation- deemed to be an assignment TN-41 Part XIII tax TN-44 taxation on conversion TN-44 Tembec Inc. et al v. ... IT-288R2 inter vivos gifts to individuals or through trusts IT-209R(SR) legal and accounting fees IT-99R5(C) owned December 31, 1971- capital cost to testamentary trust IT-130 reduction of the cost government assistance IT-273R2 Property, cultural certified IT-407R4(C) deductions as gift IT-407R4(C)- official receipts IT-96R6 disposition to designated Canadian institutions IT-407R4(C) Property, depreciable acquisition date, effect on capital cost allowance IT-285R2 amalgamation of corporations IT-474R2 capital cost allowance- class 8 property IT-472(SR)- deductibility IT-128R clearing or levelling cost IT-485 disposition- combined consideration IT-220R2(SR) family farm transfer to child on death IT-349R3 legal and accounting fees IT-99R5(C) petroleum and natural gas activities IT-476R proceeds of disposition IT-220R2(SR) scientific research and experimental development IT-151R5(C) Property, ecological deduction as gift- official receipts IT-96R6 Property, eligible capital bad debts on sale of IT-123R4; IT-123R6 ceasing to carry on business IT-313R2 cumulative eligible capital calculation IT-123R4; IT-123R6 deceased person's IT-313R2 eligible capital amounts received on disposition IT-386R eligible capital expenditures IT-143R3 government rights IT-313R2 inter vivos transfer of farm property to child IT-268R3(SR); IT-268R4 legal and accounting fees IT-99R5(C) new system for calculation IT-123R6 replacement property IT-259R4 transactions, accounting for IT-123R4; IT-123R6 Property, foreign capital cost allowance IT-285R2 foreign tax credit re capital gains and losses IT-395R2 registered pension plans, special tax IT-412R2 Property, identical bonds, debentures, notes, etc. ... Treaty's Competent Authority Provision Thin Capitalization Imperial Oil and the Treatment of Foreign Currency Loans SIFT Rules – Transitional Normal Growth SIFT Entities – Definition of "Real Estate Investment Trust" in Section 122.1 Paragraph 251(5)(b) – Conditional Agreements CRA Auditors' Access to Audit Working Papers Foreign Entity Classification Application of Paragraph 95(6)(b) Pension Fund Corporations Application of Subparagraph 212(1)(b)(vii) Employee Stock Option Deduction Purchase Price Allocation for Rental Properties Subsection 78(4) – Liability Assumed by a Third Party Value of Company Attributable to Voting Non‑Participating Shares Criteria for Determining Hedge Effectiveness for Tax Purposes Definition of "Non-Portfolio Earnings" in Subsection 122.1(1) Filing Requirements for T5013, Partnership Information Return Transfer of GST/HST Refunds to Non‑Resident Security Accounts Anti-Discrimination Provisions Limited Liability Company under the Protocol TN-39 Settlement of a Shareholder Class Action Suit – Compensation by Way of Cash and Shares TN-40 Administrative Policy Changes for Taxable Employment Benefits TN-41 Eligible Dividend Designation – Subsection 89(14) The "More Than Five Full-Tine Employees" Test Meaning of "Business Rulings (Opinions) on Proposed Legislative Amendments Definition of "Tax Shelter" – Subsection 237.1(1) Donation of Flow-Through Shares – Subparagraph 38(a.1)(i), subsection 248(35) through (41) and section 237.1 Date-Stamping Procedures Conversion from Canadian GAAP to IFRS Exchangeable Debenture – Paragraph 20(1)(f) Convertible Debt Transfer Pricing and Dispute Resolution Stock Benefit Withholding Requirements Loss Consolidation and Provincial GAAR Provincial Income Allocation – Section 400 of the Income Tax Regulations Deductibility of Interest on Money Borrowed to Acquire Common Shares 5th Protocol to the Canada-US Tax Convention – Hybrid Entities 5th Protocol to the Canada-US Tax Convention – Limitation on Benefits Functional Currency Tax Reporting Rules TN-42 International Financial Reporting Standards (IFRS) TN-43 Taxation of Roth IRAs TN-44 Valuation of Special Voting Shares Key Employee Tax-Free Savings Account Corporate-Held Life Insurance Paid-Up Capital Increase by an Unlimited Liability Company Luxembourg Intermediary Payments by ULC Payments by a ULC to an LLC in 2009 Treaty Forms US LLC with a Canadian Branch Exchangeable Debentures: Paragraph 20(1)(f) Unanimous Shareholder Agreements and the CCPC Definition Cost of Property Acquired from a Shareholder for No Consideration Filings Based on Proposed Changes to Law Assessments Services Provided by a US Resident to a Canadian Subsidiary of a US Customer Services Provided by a US Employee to a Canadian Subsidiary Services Provided by a US Employee to a Customer of a Canadian Subsidiary IFRS and Foreign GAAP Loss Consolidation Foreign Currency Reporting Convertible Debentures: Paragraph 20(1)(f) Convertible Debentures and Part XIII Central Paymaster Rules Calculating LRIP for Cash-Basis Taxpayers Consistency in Audit Practice Update on Committees Foreign Exchange Gains and Losses Part 5 – List of cancelled and archived bulletins since the last publication of the index None Date modified: 2012-10-16 ...