Search - consideration

As part of a corporate reorganization in XXXXXXXXXX, Parent contributed all of the issued and outstanding shares of Foreignco to DC for consideration that consisted solely of additional membership interests in DC. ...

In determining the existence of commercial coherence, factors that would be relevant include: 1) whether the projects would, in the absence of tax planning considerations, have been concluded pursuant to a single contract; 2) whether the nature of the work involved under different projects is the same; and 3) whether the same individuals are providing the services under the different projects. ...

For the purposes of the application of paragraph 5(2)(b) of the EIA, the CRA considers all the classes of voting shares of the corporation and also takes into consideration the number of votes allocated to each share. ...

As evidenced by the terms and conditions of the Term Sheet, the Corporation and the Other Shareholders have agreed that XXXXXXXXXX will purchase from the Corporation the Corporation's shares of XXXXXXXXXX for consideration consisting of the cash to be received in accordance with the terms and conditions of the Term Sheet and the value of the NSR. 14. ...

(3) Why does line 300 of T2 Schedule 53 only take into consideration eligible dividends paid in the previous taxation year? ...

The CRA made a decision not to appeal the Nassau Walnut decision (or the other decisions referred to) and, instead, to accept late-filed designations, giving due consideration to the application of certain penalty provisions. ...

As noted in paragraph six of IT-91R4, in this regard, particular consideration should be given to the following factors: the nature of the duties to be performed by the employee (certain types of work are, by their nature, short term engagements, such as repair work or trades which are involved only during a certain phase of a project); the overall time estimated for a project, or a particular phase of a project, on which the employee is engaged to perform duties; and the agreed period of time for which the employee was engaged according to the employment contract or other terms of the engagement. ...

Although not a comprehensive list, consideration could be given to the following: does a written partnership agreement exist? ...

(b) a trust governed by a registered retirement savings plan, under which the individual [Mr A] or the individual's spouse or common-law partner [Mrs A] is the annuitant [Mrs A is], that is a spousal plan in relation to the individual [Mr A] or the individual's spouse or common-law partner [Mrs A] [it is in relation to Mr A- see the definition of spousal plan below] if the individual [Mr A] and no other person claims a deduction under subsection 127.4(2) in respect of the share;" In the scenario under consideration, paragraph (a) of the definition of "spousal plan" in subsection 146(1), now "spousal or common-law partner plan", is relevant such that spousal plan in relation to a taxpayer [Mr A] "means (a) a registered retirement savings plan (i) to which the taxpayer [Mr A] has, at a time when the taxpayer's spouse or common-law partner [Mrs A] was the annuitant under the plan, paid a premium" [Mr A did pay the premium and Mrs A was the annuitant]. ...

Canco received total consideration of approximately $XXXXXXXXXX in respect of the sale of the Assets of the Business to the Purchaser. 5. ...