Search - consideration

The mortgages will be sold by the Issuer for a single consideration on a fully-serviced basis, with an undivided beneficial ownership interest in such pool represented by XXXXXXXXXX, as described in more detail below. 8. ...

Following judgment by the Court having jurisdiction, or in the event that FA and the XXXXXXXXXX authorities reach an agreement as to the compensation package for the FA Property described in paragraphs 6 and 7 above, FA will, before the end of the second taxation year following the taxation year in which the proceeds of disposition of the FA Property become receivable (taking into consideration the provision of subsection 44(2)), acquire a capital property ("New Property") that would be a replacement property described in subsections 13(4.1) and 44(5), to replace all or part of the FA Property, under terms and conditions which will qualify it to elect under section 1033 of the Internal Revenue Code ("IRC"). ...

The aggregate consideration to be paid for the XXXXXXXXXX interests will be adjusted to take into account additional capital contributions as noted below. ...

Further, amounts received by PARENT from USSubco in respect of the increase in the Bargain Element Amount that, in the circumstances, may reasonably be considered to have arisen (taking into account all relevant considerations concerning the Agreement) after the Agreement is in place on stock options that were granted prior to the date that the Agreement is entered into, will not be included in the income of PARENT under section 9 or 90, subsection 15(1) or 56(2), or paragraph 12(1)(x). ...

On the basis that the payments made under the Agreement were deductible by the payer and required to be included in the income of the recipient, you have also mentioned that for the purposes of determining whether there is a "commencement day", as defined in subsection 56.1(4) of the Act, with respect to the Order, a consideration is item XXXXXXXXXX of the Agreement which provides that there would be no change to the tax treatment of the child support unless (i) the parties mutually agree otherwise, or (ii) either Individual A or B applies to the Court to have the Child Support Guidelines apply after May 1, 1997. ...

Paragraph 6 of Interpretation Bulletin IT-239R2 Deductibility of Capital Losses from Guaranteeing Loans for Inadequate Consideration and from Loaning Funds at less than a Reasonable Rate of Interest in Non-arm's Length Circumstances, dated February 9, 1981, outlines the only situations and conditions under which the Canada Customs and Revenue Agency will not apply subparagraph 40(2)(g)(ii) of the Act. ...

The purpose of structuring the XXXXXXXXXX Commitments as a put, instead of obligating XXXXXXXXXX to purchase the remaining Common Shares, is purely commercial and is not motivated by tax considerations. ...

Is there a way for the CCRA to obtain legal advice from the Department of Justice that would then permit the GAAR Committee to maintain minutes of their considerations for release to the taxpayer? ...

This request should be forwarded to the tax services office of the employer, for their consideration, in accordance with subsection 900(2) of the Regulations. ...

In consideration for the Assignee making such payments, the Claimant agrees to settle XXXXXXXXXX claims against the Defendants. 8. ...