Search - consideration

The mortgages will be sold, on a fully-serviced basis, by the Issuer for a single aggregate consideration, with respective undivided beneficial ownership interests in such pool represented by XXXXXXXXXX. 8. ...

Pursuant to the terms of a tax-deferred reorganization in Israel, Foreign Parent will acquire from Foreign Holdco, for no consideration, the shares of Canco2 held by Foreign Holdco. ...

RCA provides guarantee or security for third-party loan to specified beneficiary You ask whether we would consider an RCA strip to have occurred if the specified beneficiary pays the RCA custodian an "arm's length commercial" fee as consideration for the RCA custodian guaranteeing, or permitting the RCA property to be used as security for, a loan made to the specified beneficiary from an arm's length financial institution. ...

That is because Canco did receive consideration for its disposition of the shares of FA1 in the form of the FA2 shares it received; and 3. unless Canco elects not to have subsection 87(8) of the Act apply, paragraph 87(4)(b) of the Act, as modified by subsection 87(8), will apply to the shares of FA2 distributed to Canco to deem them to have been acquired by Canco at a cost equal to the proceeds for which the FA1 shares were deemed disposed of pursuant to paragraph 87(4)(a) of the Act. ...

The classification of the proposed amounts to be paid to the international students, and the students’ status as full-time or otherwise of the Canadian university, are therefore important considerations in determining the taxability of the amounts. ...

Corporation A acquired the Property on XXXXXXXXXX and issued its shares as consideration for the Property. 12. ...

In the case of rental assistance received by an Indian, several factors must be taken into consideration in determining the tax status of the assistance. ...

For greater certainty, Parent will receive no consideration for the transfer of the Subject Properties. ...

Also, as noted under paragraph 7 of IT-143R3, if the portion of the total consideration for the business that is allocated to the goodwill is unreasonable, the CRA can apply the provisions of section 68 to deem what may reasonably be regarded as the amount for the goodwill. ...

Paragraph 20(1)(bb) requires consideration in the case of those fees charged to capital account and fees charged to income account that were not laid out to gain or produce income but were outlays on account of capital. ...