Search - consideration

17 September 1997 External T.I. 9721415- INTERACTION OF SUBSECTION 55(2) & DIVIDEND REFUNDS-- summary under Subsection 55(2) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2) The fact that a dividend refund has been received by the payor of a dividend is not normally relevant to consideration of the following expression: "that is not refunded as a consequence of the payment of a dividend to a corporation where the payment is part of the series of transactions or events". ...

30 November 1997 Ruling 9732433 F- UTILISATION DE PERTES LOSS UTILIZATION-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) Consideration of the reasonableness of an interest rate (8.7%) before giving favourable rulings on an arrangement respecting the deductibility of interest on money borrowed in order to redeem shares that had permitted the utilization of losses within a corporate group. ...

3 June 1994 Internal T.I. 9405427- DEDUCTIBILITY OF INTEREST UNDER 20(1)(C)-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) Consideration of interest deductibility in a situation where a loan is used to purchase preferred shares which are exchanged for common shares of a related company three months after their acquisition. ...

24 August 1994 Internal T.I. 9420517- INTEREST DEDUCTIBILITY-- summary under Subsection 20(3) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(3) Where the assets of a proprietorship are transferred to a corporation for consideration including a note payable, interest on money borrowed by the corporation from a financial institution to repay such note will be deductible. ...

6 September 1994 External T.I. 9420525- DIRECTOR-STOCK OPTIONS-- summary under Subsection 7(5) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(5) Options are received by a director in respect of an employment where the options were granted to the director in consideration for the services to be performed as director. ...

24 September 1996 External T.I. 9627705- DONATIONS/TUITION FEES-- summary under Total Charitable Gifts Summary Under Tax Topics- Income Tax Act- Section 118.1- Subsection 118.1(1)- Total Charitable Gifts Unlike teaching or other training, religious training is not viewed as consideration for purposes of the definition of a gift. ...

24 May 1995 External T.I. 9420675- WYOMING LLCS-- summary under Subsection 85(1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1) An interest in a Wyoming LLC receivable by a taxpayer as consideration for the disposition of shares of a foreign affiliate to the LLC would constitute "shares of the capital stock of the acquiring affiliate" provided that the LLC otherwise qualified as a foreign affiliate of the taxpayer immediately after the disposition. ...

-- summary under Subsection 256(1.1) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(1.1) Where a share has been issued as a stock dividend, the consideration for which the share was issued would be considered to be nil. ...

12 November 2003 External T.I. 2002-0121835- 85(1)- Holdbacks Payable-- summary under Subsection 85(1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1) On a sale by a contractor of its construction contracts to a corporate purchaser, the fair market value of builder's holdbacks assumed by the purchaser would be considered to be non-share consideration for purposes of s. 85(1). ...

9 November 1999 External T.I. 9912655- CONFIDENTIALITY COVENANT-- summary under Paragraph 6(3)(e) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(3)- Paragraph 6(3)(e) The Agency indicated that an amount paid to a dismissed employee to secure a confidentiality agreement would be described by s. 6(3)(e) as consideration for a covenant with reference to what an officer or employee would not do after the termination of the employment. ...