Search - consideration

" "except any benefit... derived from counselling services in respect of... the re-employment or retirement of the taxpayer" Subsection 6(3) "An amount received by one person from another (a) during a period while the payee was an officer of, or in the employment of, the payer, or (b) on account, in lieu of payment or in satisfaction of an obligation arising out of an agreement made by the payer with the payee immediately prior to, during or immediately after a period that the payee was an officer of, or in the employment of, the payer, shall be deemed, for the purposes of section 5, to be remuneration for the payee's services rendered as an officer or during the period of employment, unless it is established that, irrespective of when the agreement, if any, under which the amount was received was made or the form or legal effect thereof, it cannot reasonably be regarded as having been received (c) as consideration or partial consideration for accepting the office or entering into the contract of employment, (d) as remuneration or partial remuneration for services as an officer or under the contract of employment, or (e) in consideration or partial consideration for a covenant with reference to what the officer or employee is, or is not, to do before or after the termination of the employment. ...

Whenever a transaction is reviewed by an auditor the value or FMV will be an audit consideration. ... Under existing legislation, consideration may be given to waiving interest in those instances where an individual is experiencing financial hardship and has no ability to pay the liability in full. ... The GAAR has been recommended for consideration in 26 of these cases. ...

The authorized share capital of Investco consists of: (a) an unlimited number of non-voting Class AX preferred shares with a non-cumulative dividend not exceeding XXXXXXXXXX% per annum, redeemable and retractable for an amount equal to the consideration for which such shares were issued (i.e., $XXXXXXXXXX per share); (b) an unlimited number of non-voting Class BY preferred shares with a non-cumulative dividend not exceeding XXXXXXXXXX% per annum, redeemable and retractable for an amount equal to the consideration for which such shares were issued (i.e., $XXXXXXXXXX per share); (c) an unlimited number of voting Class V preferred shares (one vote per share) with no dividend entitlement, retractable for an amount equal to the consideration for which such shares were issued (i.e., $XXXXXXXXXX per share); (d) an unlimited number of voting Class A common shares (one vote per share); and (e) an unlimited number of non-voting Class B common shares, convertible into Class BY preferred shares at the option of the shareholder on a one-for-one basis. 3. ... Subject to the application of subsection 69(11), the provisions of subsection 85(1) will apply to: (a) the transfer of the shares of Investco held by the Trust to the XXXXXXXXXX Holdcos, as described in Paragraph 27 above; and (b) the transfer of Investco's property to the XXXXXXXXXX Holdcos, as described in Paragraph 30 above; such that the agreed amount in respect of each such transfer will be deemed to be the transferor's proceeds of disposition of the property and the transferee's cost thereof, and the transferor's cost of the shares received as consideration for the disposition. ...

As consideration for the purchase of the Land Option, TC paid cash of $XXXXXXXXXX to DC. ... As consideration for the transfers, Holdco issued its shares to each of Individuals D and E. ... As consideration for the transfer of property described herein, TC will: (f) assume certain liabilities of DC that will not exceed the aggregate agreed amounts in the joint elections under subsection 85(1) described in paragraph 14 below. ...

TC1 will redeem the XXXXXXXXXX Shares in its capital owned by DC for an amount per share equal to the XXXXXXXXXX Share Redemption Amount and TC1 will issue to DC in consideration therefor a demand, non-interest-bearing promissory note (the "TC1 Note") with a principal amount and FMV equal to the aggregate XXXXXXXXXX Share Redemption Amounts of the XXXXXXXXXX Shares so redeemed. ... TC2 will redeem the XXXXXXXXXX Shares in its capital owned by DC for an amount per share equal to the XXXXXXXXXX Share Redemption Amount and TC2 will issue to DC in consideration therefor a demand, non-interest-bearing promissory note (the "TC2 Note") with a principal amount and FMV equal to the aggregate XXXXXXXXXX Share Redemption Amounts of the XXXXXXXXXX Shares so redeemed. ... TC3 will redeem the XXXXXXXXXX Shares in its capital owned by DC for an amount per share equal to the XXXXXXXXXX Share Redemption Amount and TC3 will issue to DC in consideration therefor a demand, non-interest-bearing promissory note (the "TC3 Note") with a principal amount and FMV equal to the aggregate XXXXXXXXXX Share Redemption Amounts of the XXXXXXXXXX Shares so redeemed. ...

Il sera explicitement fait mention dans les caractéristiques des actions de catégorie "C" que le "montant indiqué" aux fins du paragraphe 191(4), sera désigné par résolution des administrateurs lors de leur émission, sans excéder la JVM de la considération reçue lors de leur émission. ... Les XXXXXXXXXX actions de catégorie "A" du capital-actions de chacune des NOUCOS seront émises pour une considération en argent de XXXXXXXXXX $. 15. ... IMMOCO pourrait procéder à l'émission d'actions de catégorie "B" de son capital-actions en faveur de PORTCO1, PORTCO3 et PORTCO4, pour une considération totale en argent d'un montant correspond au prix payé par IMMOCO pour les immobilisations corporelles de OPCO (tel que décrit au paragraphe 18 ci-dessous), répartie également pour chaque action de catégorie "B". ...

In consideration for agreeing to pay the indebtedness of Canco #3 XXXXXXXXXX, Canco #3 will issue a note (the "Canco #3 Note") to Canco #2 in the amount of $XXXXXXXXXX. ... Canco #3 will pay a fee (the "Loan Assumption Fee") to Canco #2 in the amount of $XXXXXXXXXX, as consideration for Canco #2 agreeing to assume the indebtedness described in this paragraph. 14. ... Canco #3 agreed to pay $XXXXXXXXXX (the "License Amendment Fee") to Canco #2 as consideration for Canco#2 agreeing to amend the License Agreement. ...

Bco will subscribe for Lossco Common Shares for nominal consideration. ... Cco will subscribe for Newco 1 Common Shares for nominal consideration. 22. ... Dco will subscribe for Newco 2 Common Shares for nominal consideration. 28. ...

Considerations: a) trader or dealer recognizes all transactions on income account b) adventure in the nature of trade c) intention of taxpayer includes secondary intention d) number of frequency of transactions e) length of holding time f) method of disposition g) nature of the transaction 2. ... [*Note: A novation occurs when an original obligation is discharged by agreement of the parties and a new obligation with new consideration is undertaken, usually, but not necessarily, on the same terms, with a different creditor or debtor. ... Instead, it is viewed as inherent in the determination of any gain or loss on the forward contract, which gain or loss can only be determined at the time of contract fulfillment and is equal to the difference between the payment made under the contract and the Canadian-dollar value of the consideration received therefor, where such consideration is translated to Canadian dollars at the spot rate in effect on the date of delivery. ...