Search - consideration

The scenario you have described results in an employee disposing of the employee’s rights under a stock option for consideration equal to the stock option’s intrinsic or in-the-money value where the consideration is paid in employer treasury shares. ...

4 August 2016 Internal T.I. 2016-0645521I7- 90(6) & sale of creditor affiliate Unedited CRA Tags 90(6); 90(8)(a); 90(14) Principal Issues: Whether the exception in 90(8)(a) would apply where the "creditor affiliate" is sold for cash consideration before the 2-year time limit? ... Facts For illustrative purposes, we will use the following assumed facts: • A non-resident corporation (Foreign Parent) owns all the issued and outstanding shares of a corporation resident in Canada (Canco) and another non-resident corporation (SisterCo). • Canco owns all the issued and outstanding shares of another non-resident corporation (FA). • In 2013, FA makes a loan to SisterCo. • Before the expiration of the two year time limit specified in paragraph 90(8)(a), Canco sells its shares of FA to Foreign Parent for cash consideration. • The loan remains outstanding for more than two years. ...

Parent will receive new shares of Canadian Parent as consideration for its shares of Holdco and Canadian Parent will receive all of the shares of Amalco as consideration for its shares of CanSub. ...

The CRA generally defines a superannuation or pension plan to be a plan where contributions have been made to the plan by or on behalf of an employer or former employer of an employee in consideration for services rendered by the employee and contributions are used to provide an annuity or other periodic payment on or after the employee's retirement in consideration for his or her employment services, and, in some cases, where amounts have been contributed under the plan by a government. ...

Reasons: Consultations took into account the administrative feasibility and tax policy considerations. ... A consultation process was undertaken in which consideration was given to the formulaic approach for the computation of stub period income for participants of joint ventures. ...

"Issued Share" means one of the Class A preferred shares to be issued by Newco to the Estate in partial consideration for the Transferred Shares, the aggregate of which is referred to as the "Issued Shares"; 4. ... "Promissory Note" means the promissory note having a principal amount of $XXXXXXXXXX to be issued by Newco to the Estate in partial consideration for the Transferred Shares; 5. ...

Generally, a plan will be considered a superannuation or pension fund or plan where contributions have been made to the plan by or on behalf of an employer or former employer of an employee in consideration for services rendered by the employee and the contributions are used to provide an annuity or other periodic payments on or after the employee's retirement in consideration for his or her employment services. ...

In your email, you raise the possibility whether a transaction, where property with an intrinsic value of zero is contributed to a TFSA for no consideration, might result in an advantage as defined in subsection 207.01(1) of the Income Tax Act (the "Act"). In our view, it may not be reasonable to expect that in an open market where two taxpayers are dealing with each other at arm's length, that one taxpayer would dispose of, in your example 5,000 warrants, for no consideration. ...

If the amount of the gift is significant, however, consideration may be given to the application of subsection 8(5) with respect to the employee's deduction of union dues. ... If the gift were significant, however, consideration may be given to the application of subsection 8(5) with respect to the employee's deduction of union dues. ...

Therefore, an investment that an annuitant wants to take out of an RRSP because it has little or no value can be withdrawn or sold from the RRSP to anyone for fair market value consideration. If the property is transferred for no consideration, there will be no tax consequences as long as the fair market value of the property was nil at the time of the transfer. ...