Search - consideration

In consideration, the Taxpayer received XXXXXXXXXX Preference Shares of the capital stock of Forco. ...

When determining if an estate created on someone's death has a connected contributor, the relevant consideration is whether the deceased was a resident of Canada immediately before death or within 18 months of death. ...

13 April 2015 External T.I. 2012-0449141E5 F- Usufruct CRA Tags 248(3) Principales Questions: What are the tax consequences of the creation and termination of an usufruct created for consideration? ...

MRN, 59 DTC 1119: In deciding upon the meaning of income, the Courts are faced with practical considerations which do not concern the pure theorist seeking to arrive to some definition of that term, and where it has to be ascertained for taxation purposes, whether a gain is to be classified as an income gain or capital gain, the determination of that question must depend in large measure upon the particular facts of the particular case. ...

Generally, an amount paid to an employee as consideration for services rendered will be taxable as income from an office or employment. ...

Provided that (i) the Price Adjustment clause is valid, (ii) it is still possible to adjust the price of the common shares agreed upon, the value of the preferred shares received and the consideration given for the preferred shares redeemed or sold and (iii) the terms of the clause have effectively been implemented, the CRA will take that Price Adjustment clause into account when considering whether the conditions to apply subsection 75(2) are met. ...

Whether a factual adoption has occurred at a particular time is a question of fact and has to be determined based on a consideration of the particular circumstances. ...

In the example under consideration, since the interest is determined by reference to a public benchmark commodity index and not with reference to the value of any specific property on the debtor's balance sheet, the interest would not be captured by subparagraph 6(b) of Article XI of the Treaty. ...

You have requested our opinion on whether consideration could be made to the application of the penalties provided by subsections 162(5) and 162(7) to the incomplete foreign reporting forms in order to facilitate compliance. ...

As with the determination of carrying on business in Canada, the determination of whether Part XIII withholding tax applies to any payments from Canada to USCo or whether the payments would qualify under the above noted exception could only be made upon consideration of all the relevant facts, including the exact nature of the license agreement between USCo and the Canadian payor. ...