Search - consideration

Your position is based upon the fact that, under the relevant corporate statutes, upon redemption, cancellation or acquisition of a class of shares the holder could be entitled to receive the fair market value of the consideration for which the shares were issued, the amount of any unpaid dividends (meaning declared but unpaid) and the amount of dividends which have accumulated, but which have not been previously declared or paid whereas the provisions of paragraph 256(1.1)(e) of the Act provide that upon redemption, cancellation or acquisition of the class of shares, the redemption amount cannot exceed the fair market value of the consideration for which the shares were issued and the amount of any unpaid dividends. ...

Employment income received by an employee is a valuable consideration for the services he renders under a written or verbal employment contract. Dividend income received by shareholders is, in our view, a pro-rata distribution by a corporation among its shareholders of its income or capital gains, as consideration for the capital the shareholders have invested by buying shares of the corporation. ...

If on the other hand, the principal residence was acquired with the funds of the lower income earning spouse, the exchange of assets would be a transfer for fair market consideration as contemplated by subsection 74.5 of the Act, provided that the value of the property transferred (50% of principal residence) was equal to the value of the consideration received (the proportionate share of the investment portfolio). ...

As indicated in our letter we also advised that, as the other issues were payroll matters, we were forwarding the request for a ruling on to you for consideration. ... He further states, "however, I do think that the place where the benefits are paid to the plaintiff should be a consideration when assessing situs for the benefits, based on Dickson, J.'s comments in Nowegijick". ...

As indicated in our letter we also advised that, as the other issues were payroll matters, we were forwarding the request for a ruling on to you for consideration. ... He further states, "however, I do think that the place where the benefits are paid to the plaintiff should be a consideration when assessing the situs for the benefits, based on Dickson, J.'s comments in Nowegijick".  ...

In this regard, we have addressed this matter with the International Taxation Office and consideration will be given to the issuance of a registration number under the TEDS system. 24(1) As in the case of 24(1) we see no reason not to issue a registration number under the TEDS system and in this regard we have sent a copy of the additional information provided to the International Taxation Office for consideration. 24(1) We have spoken with officials in the International Taxation Office who will consider issuance of a registration number. ...

Due to the elected amount and the amount of non-share consideration received on the transfer these preferred shares have a cost of nil pursuant to paragraph 85(1)(g) of the Act. 2. ... No consideration other than common shares will be received on the conversion. ...

Fontaine 613-995-1723 July 25, 1980 Dear Sirs: This will reply to your letter dated May 29, 1980 wherein you request our views on the treatment to be accorded the consideration ascribed to a building in a sales agreement and purchased only because it was necessary to do so to acquire the land on which it was situated. ... Where, in a situation such as you have described, the total sale price (of the property, including the building) is not in excess of the fair market value of comparable land, it may be reasonable to conclude that the sale was essentially one of land and that the price was in consideration only of land, even though the building was still usable and may have had some value to the vendor. ...

A, agreed to guarantee the $300,000 bank loan in consideration of Mr. ... In our view, a debt cannot be considered to have been acquired for such a purpose unless the guarantee is made in return for some reasonable consideration. ...

The question under consideration is the taxability of the interest on the excess contributions. ... In the unusual circumstance that the above considerations do not apply, it would seem that the income would be subject to tax; likely as the income of a trust. ...