Search - consideration

Paragraph 118.2(2)(q) of the Act provides that a premium, contribution or other consideration under a PHSP is a medical expense of an individual for the purposes of subsection 118.2(1) of the Act if they are paid in respect of the persons listed in paragraph 118.2(2)(q), except to the extent that a deduction under subsection 20.01(1) of the Act is available. ...

The Board will terminate the Plan on the XXXXXXXXXX with the consent of the Participants and in consideration of such termination each Participant will be granted the right to be paid a cash settlement amount (the "Settlement Amount") on any business day between XXXXXXXXXX and XXXXXXXXXX (the "Settlement Date"). ...

In consideration for providing a turn-key operation for a restaurant by providing leased premises, training, equipment and supplies, the franchisee pays an up-front franchise fee as well as ongoing contributions towards the operation of the franchise (such as contributions to an advertising fund) and also pays a monthly royalty payment based on its gross sales. ...

Since the Act does not specify the point at which such entitlement arises, it must be determined based upon a review of the relevant facts of each particular situation, taking into consideration the ordinary meaning of the word 'entitled.' In order for a taxpayer to be 'entitled to receive' an amount, the taxpayer must have a clear legal right to receive the amount, and all of the pre-conditions to a 'right to receive' the amount must have been satisfied. ...

Holdco1 will subscribe for XXXXXXXXXX common shares of Subco, which will constitute all the outstanding shares of Subco, in consideration for which it will pay a nominal amount to Subco. 19. ...

Accordingly, given your concern that an annuity received as a consequence of an individual's participation in a foreign pension scheme may be inappropriately taxed, you may wish to refer this matter to the Department of Finance for their consideration in the finalization of the proposed legislation. ...

This factor was a major consideration in agreeing to the Settlement. 10. ...

In consideration of the Insurers making such payments, the Claimant settles XXXXXXXXXX claims against the Defendants. ...

Paragraph 260(8)(b) provides that where the borrower of securities has provided the lender with money, either as collateral or as consideration for the securities, and the borrower does not pay or credit a reasonable amount to the lender as a fee for the use of the securities, an amount calculated under that paragraph is deemed to be an amount paid under the arrangement by the borrower to the lender as a fee for the use of the securities. ...

(ii) the development of real estate for sale, the lending of money, the leasing or licensing of property or the insurance or reinsurance of risks, and (b) the affiliate...employs (i) more than 5 employees full time in the active conduct of the business, or (ii) the equivalent of more than 5 employees full time in the active conduct of the business taking into consideration only the services provided by its employees of (A) a corporation related to the affiliate (otherwise than because of a right referred to in paragraph 251(5)(b)),... where the corporation...referred to in clause (A) receive compensation from the affiliate...for the services provided to the affiliate...by those employees the value of which is not less than the cost to such corporation...of the compensation paid or accruing to the benefit of those employees that perform the services during the time the services were performed by those employees. ...