Search - consideration

XXXXXXXXXX souscrira à XXXXXXXXXX actions ordinaires de Newco pour une considération de XXXXXXXXXX$. ... XXXXXXXXXX souscriront à XXXXXXXXXX actions de catégorie «XXXXXXXXXX» d'Opco pour une considération de XXXXXXXXXX $ dans les proportions de XXXXXXXXXX % et de XXXXXXXXXX % respectivement. ...

Principal Issues: Calculation of the capital gain arising from the release of a remainder interest in farm land for no consideration. ... The release and transfer by XXXXXXXXXX of their remainder interests to their mother for no consideration will result in a disposition of their interests for deemed proceeds of disposition equal to the FMV of those interests at the time they are disposed of (pursuant to paragraph 69(1)(b) of the Act). ...

The application of these provisions to a particular case can only be made after thorough consideration of all of the relevant facts pertaining to that situation. ... Whether a particular asset is capital property used by a person in carrying on a business (other than an insurance business) in Canada such that the asset is taxable Canadian property by virtue of subparagraph 115(1)(b)(ii) is essentially a question of fact that can only be answered after determination of all relevant facts pertaining to the particular case under consideration. ...

Ainsi, Opco offrirait aux membres actuels l'opportunité de souscrire à des actions ordinaires de son capital-actions pour une considération nominale, c'est-à-dire possiblement pour une valeur inférieure à la juste valeur marchande de ses actions, et ce, en parts égales entre les membres. ... L'émission d'actions ordinaires par Opco à d'anciens membres pour une considération nominale ne constituera pas un avantage pour ceux-ci au sens de l'article 15 de la Loi. 5.       ...

In commenting on the reference to "heirs, executors or assigns" in the definition of "refund of premiums", we advised you by memorandum of March 9, 1983 (copy enclosed), that the phrase was to be read only in the context of the definition; it was our view that the word "assign" did not refer to an assignee for consideration but rather to the named beneficiary of the RESP. We went on to state that the subscriber could be permitted to assign for consideration the right to a refund of payments, but assignment of the right to designate the beneficiary under the plan could subvert the purpose for which the plan was originally set up and should be resisted. ...

XXXXXXXXXX Cet abandon pure et simple sera fait sans considération ou indication de la personne devant bénéficier de celle-ci. ... XXXXXXXXXX Cet abandon pur et simple sera fait sans considération ou indication de la personne devant bénéficier de celle-ci. ...

On XXXXXXXXXX, Holdings redeemed XXXXXXXXXX second preferred shares for a cash consideration of $XXXXXXXXXX. ... The Trust will not receive any consideration as a result of the resettlements. ...

Distributorco will satisfy the payment of these dividends by issuing to Transferee as consideration XXXXXXXXXX separate demand promissory notes, each bearing interest not exceeding the prime rate of borrowing plus XXXXXXXXXX% only after demand is made. ... The day after the payment of the common share dividends, described in Paragraph 13 above, Transferee will redeem the XXXXXXXXXX Class A voting shares owned by Shareholder 1 and the XXXXXXXXXX Class A voting shares owned by Shareholder 2 for cash consideration of $XXXXXXXXXX and $XXXXXXXXXX respectively, equal to the fair market value of the shares. ...

The CCRA's response It should first be noted that the text of this question only summarizes very briefly a hypothetical situation (the "Given Situation") and, among other things, does not provide information about the consideration received by the selling shareholders and the use of Opco's assets after the transaction is completed. ... It is also difficult for us to take a definitive position on the potential application of section 84.1 in the Given Situation because the text of this question only summarizes very briefly the Given Situation and, among other things, does not provide any information about the consideration the selling shareholders would receive, or if the selling shareholders are not dealing at arm's length or are deemed not to be dealing at arm's length with the purchaser. ...

In this case, provided that the rent to the Charity represents fair market value, the lease with the donor would not be regarded as consideration or benefit received by the donor with the result that the proposed transfer would constitute a gift. ... COMMENTS Draft amendments originally released by the Department of Finance on December 20, 2002 and included in the revised package of draft amendments released on February 27, 2004 propose to recognize a gift, for tax purposes, in certain circumstances where a donor has received consideration or other benefit for property transferred to a registered charity or qualified donee after December 20, 2002. ...