Search - consideration
Results 8011 - 8020 of 29012 for consideration
Miscellaneous severed letter
28 December 1989 Income Tax Severed Letter 5-8491 - Tax treatment of several arrangements which charitable organizations are either using or contemplating using in connection with their fund-raising activities
In consideration for the capital contribution, the charity undertakes to pay the donor a specified amount for the life of the donor. ... You mention that the consideration for the issue of an annuity would be the lesser of the capital contribution and the amount that would be charged by a commercial annuity issuer. ... In your view, IT-111R appears to treat the excess of the individual's contribution over the gift recognized as the consideration for the annuity issued by the charity, and as such you assume that the gift component that is not recognized (the difference between the consideration for the annuity as determined in IT-111R and the amount that would be charged by a commercial annuity issuer) is considered to be an annuity reserve. ...
Conference
3 May 2022 CALU Roundtable Q. 9, 2022-0928891C6 - Subsection 104(6)
For trust law purposes, the trust receives the cash consideration as a part of its capital (none of the provisions of the trust deem the proceeds from the redemption of shares to be ‘income’ of the trust). The trustees distribute the cash consideration as a capital distribution to the capital beneficiaries of the trust before the end of the trust’s taxation year in which the shares were redeemed. ... To the extent that any payment of the amount is made in-kind, other legal and tax considerations would need to be taken into account. ...
Miscellaneous severed letter
28 June 1990 Income Tax Severed Letter ACC9596 - Stock Bonus Plan
Appeals' position: Par. 2 of IT 113R3 defines issue as: "to deliver unissued shares of a corporation including unissued shares for no monetary consideration." ... The word "issue" means to issue treasury shares of a corporation, including an issue of treasury shares for no monetary consideration. ... I would be reluctant to state in the bulletin that Sec. 7 does not apply where a corporation has to reacquire its own shares before transferring them (for no consideration) to an employee. ...
Miscellaneous severed letter
27 April 1988 Income Tax Severed Letter 7-2426 - [Capital Gains Exemption on Small Business Corporations]
The provisions of paragraph 110.6(7)(b) of the Act would not apply as property has not been acquired by a corporation for consideration that does not approximate the fair market value of the property. ... Similarly, if the adjusted cost base of the property to be transferred is based on a V-day valuation, then the appropriate minimum amount of the consideration should be equal to the V-day value of the property. If the property to be transferred is depreciable property and the transferor had unexpired non-capital losses at the time of the rollover, these losses would affect the amount of consideration that would be acceptable. ...
FCTD
Samoth Financial Corp. Ltd. v. The Queen, 85 DTC 5473, [1985] 2 CTC 275 (FCTD), aff'd 86 DTC 6335, [1986] 2 CTC (FCA)
Pursuant to a contract in writing made the 18th day of November, 1974, Samoth acquired from Century 21 US in consideration for the sum of $100,000 the exclusive right to sell Century 21 franchises to licensed real estate brokers in the Dominion of Canada and to use the Century 21 name, service marks and systems in connection therewith. 5. ... This Agreement is being entered into by Century 21 in reliance upon and in consideration of the singular skill, qualifications and representations of the present officers and shareholders of Subfranchisor who will actively participate in the ownership and operation of the purchased business. ... FRANCHISE: For and in consideration of the initial franchise fee to be paid by Franchisee to Century 21 and the execution of this Agreement, Century 21 hereby grants to Franchisee, and Franchisee hereby accepts a franchise to operate a Century 21 Real Estate Brokerage Office. ...
FCTD
Wargacki v. The Queen, 92 DTC 6336, [1992] 1 CTC 269 (FCTD)
He was given an option to buy 2,000 warrants to purchase Class "B" common shares in the company at the price of $2 per warrant or a total consideration of $4,000. ... (hereinafter called the "Shares"); NOW THEREFORE THIS AGREEMENT WITNESSETH that in consideration of the sum of ONE ($1) DOLLAR and other good and valuable consideration paid by the Employee to the Company (receipt whereof is hereby acknowledged by the Company), and in consideration of additional sums of money to be paid by the Employee to the Company as hereinafter set forth, the parties hereto agree as follows: 1. ... He explained that the stock option plan (1981) giving the right to an employee to a one-time purchase or all option shares paid by a loan repayable over five years was to provide consideration so that the employee would have the shares. ...
TCC
Centre Hospitalier Le Gardeur c. La Reine, 2007 TCC 425
Brown, the first question to answer is: what was supplied in consideration of the payment? ... Whether the services are rendered under a single contract, or for a single undivided consideration, are matters to be considered, but for the reasons given above are not conclusive. ... [68] The same reasoning has also been used in many other tax cases. [57] As Judge Rip stated, the first thing to be determined is what was supplied in consideration of the payment made. ...
TCC
Massignani c. M.R.N., 2004 TCC 75
In the opinion of the judge, it was a contract based on an unlawful consideration contemplated in article 989 of the C.C.L.C. ... In my view, there was no such consideration in these contracts of employment. ... The consideration, in this case, was the provision of services for Tiva, and wages for the Appellants. ...
FCTD
Committe for Monetary and Economic Reform v. Canada, 2014 FC 380
The issues in the Claim are policy-laden and raise broad economic considerations. ... This allows for discretion and consideration of policy in the implementation of those powers under the Bank Act. ... * The Court should take a liberal and generous approach in its consideration of the matter ...
FCA
Martin v. Canada (Attorney General), 2013 FCA 15
As such, it cannot reasonably be construed as making any suggestion as to the concern, respect and consideration that the parents of twins deserve. ... Such considerations are as compelling in the case of Charter challenges to a tribunal’s enabling statute. ... Surely claimants in these situations would argue that their increased needs are no less worthy of consideration than the needs of parents of twins. ...