Search - consideration

We also share the view expressed by the Tax Court of Canada in Piuze et al v The Queen (footnote 3) in that: “In law, the allocation of a corporation’s profits to shareholders by dividends does not constitute remuneration for their work, any more than that work constitutes consideration for dividends received.” ...

., voluntary transfers of property for no consideration) are not subject to tax in the hands of the recipient. ...

Paragraph 400(2)(c) states: For the purposes of this Part, "permanent establishment" in respect of a corporation means a fixed place of business of the corporation, including an office, a branch, a mine, an oil well, a farm, a timberland, a factory, a workshop or a warehouse, and (c) an insurance corporation is deemed to have a permanent establishment in each province and country in which the corporation is registered or licensed to do business; Paragraph 400(2)(c) does not indicate that it is an exclusive (“notwithstanding”) or exhaustive (“means”) provision such that it would prevent consideration of any situation other than as described in this paragraph that would cause the taxpayer to otherwise have a PE, such as where a taxpayer as a partner has a PE in a province due to the partnership’s PE. ...

X subscribes to new common shares of the capital stock of the non-SBC for nominal consideration. ...

Interpreted in context, however, the phrase would generally encompass a large group of persons dealing with a financial institution at arm’s length who have been offered the same incentive without regard to tax considerations or their other personal or financial circumstances. ...

In some instances, a note was issued by the corporation to the estate as consideration for the redemption of a portion of its shares held by the estate; and some of the proposed transactions contemplated the corporation liquidating some of its assets in order to repay this note before the Pipeline Note is repaid. ...

Generally, a plan will be considered to be a pension plan under the Act where contributions have been made to the plan by or on behalf of an employer or former employer of an employee in consideration for services rendered by the employee and the contributions are used to provide an annuity or other periodic payment on or after the employee’s retirement. ...

These threshold amounts are determined with reference to expenditures incurred, on property that is part of the project, after 1989 and during years ending after the project commenced and at least 358 days before the beginning of the year under consideration. ...

X subsequently acquired shares of YCo for consideration consisting of the XCo shares. ...

Administrative relief in this regard would require further consideration and consultation with various areas in the CRA. ...