Search - consideration

The Class XXXXXXXXXX Preferred shares and Common shares will not at any time on the effective date of continuance, or at any time thereafter, be: a. the subject of any undertaking that is referred to in subsection 112(2.2) as a “guarantee agreement”; b. the subject of a dividend rental arrangement; c. the subject of any secured undertaking of the type described in paragraph 112(2.4)(a); or d. issued for consideration that is or includes: i. an obligation of the type described in subparagraph 112(2.4)(b)(i), other than an obligation of a corporation that is related (otherwise than by reason of a right referred to in paragraph 251(5)(b)); or ii. any right of the type described in subparagraph 112(2.4)(b)(ii). 2. ...

Given the broad nature of these provisions, where a private foundation is a beneficiary under an alter-ego trust, consideration must be given to subsections 188.1(3.3) to (3.5) for the purposes of determining the private foundation’s excess corporate holdings percentage and divestment obligation percentage for a taxation year. ...

Could the CRA advise if there are any insurance products or strategies (other than “Golini” type strategies) that are subject to specific audit programs or are under consideration by the GAAR Committee? ...

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

While the determination would require a review of all relevant connecting factors and consideration as to how much weight should be given to each factor, the major determining factor is the source of the income. ...

In such circumstances, in our view, it must be taken into consideration that where an arrangement creates an artificial connection between business income and a reserve, the arrangement will carry no weight as a connecting factor. ...

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

Whether an amount received as a gift or prize is taxable is a question of fact which can only be determined by analyzing all of the circumstances in a given situation Generally, however, amounts received as gifts (that is, voluntary transfers of real or personal property without consideration) or prizes are not subject to tax in the hands of the recipient. ...

Whether a particular amount is an advance on account of future earnings or a bona fide loan is a question of fact to be determined after consideration of all the relevant circumstances. ...

In your letter you indicate that subsection 148(8) of the Act provides for a tax free rollover on the disposition of a policyholder’s interest in a life insurance policy where, inter alia: (a) the policyholder’s interest in such a policy is transferred to the policyholder’s child for no consideration, and (b) a child of the policyholder or a child of the transferee is the person whose life is insured under the policy. ...