Search - consideration

., payments to Canadian authors in order to compensate them for the free access to their works in Canadian libraries "would be in respect of their independent literary or artistic activities" rather than (royalty) "payments… made in consideration for the use of, or the right to use, the work being lent out (or their copyright in the work)," so that in the case of a resident of Ireland receiving a PLRP payment, that payment would be taxable in Canada only to the extent that the author has a fixed base in Canada for the purposes of performing their "professional services" and only to the extent the PLRP can be attributed to that fixed base. ...

20 December 2013 External T.I. 2013-0501831E5- Partnership- 85(2), (3) and 100(2)-- summary under Subsection 85(3) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(3) negative ACB partnership interest A general partnership will transfer its goodwill, having a nil cost amount, to Corp under s. 85(2) in return for consideration that includes shares of Corp., and will elect at $1. ...

Accordingly, the charitable organization transferred the intellectual property rights to the technology to a newly incorporated taxable Canadian corporation (the "Corporation") in consideration for shares, with a view to gifting those shares to a public foundation (the "Foundation"), which was governed by an independent board, and is represented to deal at arm's length with the charitable organization. ...

10 October 2014 APFF Roundtable, 2014-0538621C6 F- Disposition en contrepartie de 1$-- summary under Paragraph 69(1)(c) Summary Under Tax Topics- Income Tax Act- Section 69- Subsection 69(1)- Paragraph 69(1)(c) treatment of transfer for nominal consideration as "gift" turns on Quebec law Does CRA consider, similarly to Revenu Québec, that a transfer of an immovable for $1 can be a gift? ...

Does CRA agree that the additional contributions would not constitute consideration payable for a beneficial interest in the Trust? ...

A s. 60(j)(i) transfer is not available as the PPS is not a superannuation or pension plan given the CRA policy that such a plan is one to which "contributions have been made to the plan by or on behalf of an employer of an employee in consideration for services rendered by the employee and the contributions are used to provide the employee with an annuity or a pension on or after the employee's retirement," whereas here only the taxpayer had made contributions. ...

A s. 60(j)(i) transfer is not available as the PPS is not a superannuation or pension plan given the CRA policy that such a plan is one to which "contributions have been made to the plan by or on behalf of an employer of an employee in consideration for services rendered by the employee and the contributions are used to provide the employee with an annuity or a pension on or after the employee's retirement," whereas here only the taxpayer had made contributions. ...

5 October 2012 APFF Roundtable, 2012-0454241C6 F- Double imposition-- summary under Section 325 Summary Under Tax Topics- Excise Tax Act- Section 325 double taxation from contemporaneous ITA/ETA assessments avoided by ITA assessment being 1st A, who is indebted to each of CRA and Revenue Quebec (ARQ) for $50,000, transfers $10,000 of property to A's spouse (B) for no consideration. ...

12 November 2013 Internal T.I. 2013-0497611I7 F- Feuillet T1204-- summary under Subsection 237(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 237- Subsection 237(2) T1204 disclosure applicable only where contract with federal supplier and includes travel reimbursements as “services” consideration Should reimbursements for travel expenses of external consultants to a federal agency be included on the T1204 form? ...

A) held 1 Class B discretionary-dividend common share (issued at the same time as the Class A shares), which she has transferred under s. 85(1) to a new Holdco, CRA accepts (subject to Part IV tax considerations) the tax-free payment of all of Opco’s safe income on the 1 Class B share and, in particular, that that the fair market value of the Class B share immediately before the dividend payment reflects the amount of the declared dividend. ...