Search - consideration

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

In this respect, the Act requires the following factors to be taken into consideration: a) the nature, organization and operation of any non-resident entity and the form of, and the terms and conditions governing, the investor’s interest in, or connection with, any non-resident entity; b) the extent to which any income, profits and gains that may reasonably be considered to be earned or accrued, whether directly or indirectly, for the benefit of any non-resident entity are subject to an income or profits tax that is significantly less than the income tax that would be applicable to such income, profits and gains if they were earned directly by the investor; and c) the extent to which the income, profits and gains of any non-resident entity for any fiscal period are distributed in that or the immediately following fiscal period. ...

Consideration should be given to whether or not the actions or contributions of a particular individual vis-A-vis the patient are of such a nature and degree that they could be said to constitute support of the patient and that a relationship of factual dependency can be said to exist, i.e., reliance on that support. ...

In consideration of the Assignee making such payments, the Claimant settles his claim against the Defendants. ...

The Tax Court of Canada dismissed the taxpayer’s appeal and found that the payment was taxable since it resulted from an obligation under the agreement with the employer, and was received as consideration for accepting the office within the provisions of paragraphs 6(3)(b) and (c) of the Income Tax Act (the “Act”). ...

Le fait que le même privilège soit accordé à des employés qui ne sont pas des actionnaires constituerait un facteur important, même s’il ne serait pas le seul pris en considération. ...

Blair Sixsmith, Assistant Director of Verification, Enforcement, Vancouver Tax Services Office, 15th Floor, 1166 West Pender Street, BC, V6E 3H8 for his consideration. ...

Rather, in the scenario presented, the income beneficiary has in fact disposed of his or her interest for consideration, in which case, as described above, unless the terms of the trust are varied, the remaining beneficiaries would only be entitled to the capital upon the death of the beneficiary spouse. ...

If you require assistance in determining the tax consequences of a plan already in existence, you should submit all the relevant plan documentation to the appropriate tax services office for their consideration. ...

Paragraph (3) of IT-110R3 defines a gift for the purposes of the deduction or credit pursuant to subsections 110.1 or 118.1, respectively, to be a voluntary transfer of property without valuable consideration. ...