Search - consideration

However, subsections 15(1), 56(2), 245(2) and 214(3) could be considered if the consideration paid by Canco for the non-voting preferred shares exceeds the fair market value thereof. ...

By virtue of paragraph 95(2)(b) of the Act the income of a controlled foreign affiliate of a taxpayer from services is deemed to be income from a business other than an active business if the amount paid in consideration therefore is deductible in computing the income from a business carried on in Canada by any person in relation to which the affiliate is a controlled foreign affiliate. ...

Paragraph 56(1)(a) of the Income Tax Act (the "Act") lists benefits under an EBP as being superannuation or pension benefits which are excluded from consideration under that provision.  ...

In this regard, you have asked us to confirm that Safe Income attributable to a deemed dividend on the redemption of high-low preferred shares that were received as consideration for shares which had a Safe Income entitlement is fixed at the point in time that the preferred shares are issued, and does not change over time in relation to changes in the fair market value of the corporation and its shares. ...

Acquisition of Property in Contemplation of the Transfer If a particular corporation transfers property to a wholly owned subsidiary in consideration for shares and then transfers such shares to a shareholder corporation as part of a butterfly, Revenue Canada Taxation considers that the transfer to the subsidiary is part of an indirect transfer of the property of the particular corporation to a transferee and that paragraph 55(3)(b) would not apply unless the subsidiary is wound up following the transfer of its shares to the shareholder corporation. ...

Concurrently with the issue of the new preference shares, Famco also issues additional common shares to the Son in consideration for a subscription price equal to their fair market value (based on the fair market value of an existing common share of Famco held by the Son). ...

We would further suggest that any exceptions to this position be referred to this Directorate for consideration on a case by case basis. ...

Ainsi des considérations judiciaires ont été faites par les cours anglaises sur la portée d'application des mots garde et surveillance. ...

Jack mentionnent: "The calculation of a gross premium, i.e. that actually charged by the life insurance company involves consideration of the actual mortality, interest, and expenses being experienced or expected to be experienced during the life of the policy... ...

Although a memorandum in our research files (working papers I and J) supports the interpretation given in paragraph 3, it is not apparent that subsections 11(1) and (2) and paragraph 20(1)(t) were given adequate consideration at the time the interpretation was given. ...