Search - consideration

XXXXXXXXXX will compensate XXXXXXXXXX for differences between the interest rate and fees specified to be payable under the credit facility and the interest rate and fees agreed to by XXXXXXXXXX as consideration for the assignment. 22. ...

The reason XXXXXXXXXX shareholders who hold shares of XXXXXXXXXX in their RRSPs purchase those shares for cash prior to exchanging them for shares of XXXXXXXXXX is to fit within the exception in subparagraph 88(1)(c.3)(i) for "shares of the capital stock of the parent issued by the parent as consideration for the acquisition of the shares of the capital stock of the subsidiary by the parent". ...

We have advised the Department of Finance of the discrepancy in the income tax treatment to the Insurer of the Maturity Guarantee payment, as described above, for their consideration. ...

(i) At the Effective Time, New Targetco will issue common shares (the "XXXXXXXXXX Shares") to Canco in consideration for Canco's issuing its common shares to the Targetco shareholders. ...

In our view, a note which represents absolute or conditional payment constitutes "consideration for the transferred property" for the purposes of subsection 74.5(1) of the Act.  ...

In such cases, a better indicator of the true value of the benefit could be determined by taking into account a normal rate of return on the greater of the cost or the fair market value of the corporate asset, plus the operating costs, less any consideration paid to the corporation by the shareholder and that regardless of whether there is a lease or not. ...

We would, accordingly, agree with your conclusions that the amount received by XXXXXXXXXX upon, and in consideration of, the termination of the interest rate swap agreement should be considered to have been received by the corporation on account of income and not on account of capital. ...

In this respect, the Court expressed itself as follows: "Nevertheless, when the basic assumption relied on in reassessing under the Income Tax Act is that an alleged partnership did not exist between spouses thereby placing the onus on the appellant to establish on the preponderance of the evidence that it did exist one should, in my opinion, be guided by these considerations. ...

Such performance should be regarded as having been achieved when reasonable assurance exists regarding the measurement of the consideration that will be derived from rendering the service or performing the long-term contract. ...

Bronfman Trust decision (87 DTC), consideration would be given as to whether the structure of the arrangements is designed to conceal the true purpose of the borrowing, which was to acquire an interest in a life insurance policy, in which case interest would not be deductible. ...