Search - consideration
Results 321 - 330 of 1087 for consideration
Ruling summary
2021 Ruling 2021-0895071R3 F - Partnership Reorganization -- summary under Subsection 98(3)
Fund LP will transfer the Rollover Shares and Other Investments on a s. 97(2) rollover basis to a new LP (New LP – formed by General Partner LP as general partner and Fund LP as limited partner, and) in consideration for units of New LP, with similar terms to Fund LP, except that distributions are solely in proportion to the number of units held. ... The other former partners will sell their respective fractions of Non-Rollover Shares to Carry LP for cash consideration equaling the FMV thereof. ...
Ruling summary
2021 Ruling 2021-0895071R3 F - Partnership Reorganization -- summary under Subsection 40(3.12)
Fund LP transfers its Rollover Shares and Other Investments on a s. 97(2) rollover basis to a new subsidiary LP (New LP) in consideration for the plain-vanilla units. ... The other former partners sell their respective fractions of Non-Rollover Shares to Carry LP for cash consideration equaling the FMV thereof. ...
Conference summary
7 May 2024 CALU Roundtable Q. 3, 2024-1007101C6 - Transfer of policy to child -- summary under Subsection 148(8)
Situation 1 Subsequent to Child B’s death, Parent A transfers the policy to B’s Spouse for no consideration. ... Provided that B’s Spouse acquired this interest without consideration, it is our view that subsection 148(8) of the Act would apply to the transfer of the interest in the Policy from Parent A to B’s Spouse, such that Parent A would be deemed to have disposed of the interest in the Policy for proceeds of the disposition equal to Parent A’s ACB of the interest immediately before the transfer, and B’s Spouse will be deemed to have acquired the interest in the Policy at a cost equal to those proceeds. ...
Ruling summary
12 July 1995 Ruling File No. 11755-20 -- summary under Service
12 July 1995 Ruling File No. 11755-20-- summary under Service Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Service "A Tenant inducement is interpreted as being consideration for the supply of a service which occurs at the time the lease is signed. ...
Technical Interpretation - External summary
21 October 2014 External T.I. 2014-0543041E5 - Class 43.2 - Photovoltaic System -- summary under Class 43.2
21 October 2014 External T.I. 2014-0543041E5- Class 43.2- Photovoltaic System-- summary under Class 43.2 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 43.2 solar panels General discussion of the considerations applicable to claiming CCA on solar photovoltaic systems. ...
Technical Interpretation - External summary
7 March 1990 T.I. (August 1990 Access Letter, ¶1387) -- summary under Subsection 146.3(6)
(August 1990 Access Letter, ¶1387)-- summary under Subsection 146.3(6) Summary Under Tax Topics- Income Tax Act- Section 146.3- Subsection 146.3(6) Where the surviving spouse is not named as beneficiary in either the RRIF application or the will but is the sole beneficiary of the will, the taxpayer should submit complete details in writing to his local district taxation office for consideration. ...
Technical Interpretation - External summary
3 December 1990 T.I. (Tax Window, Prelim. No. 2, p. 11, ¶1062) -- summary under Subsection 80(1)
No. 2, p. 11, ¶1062)-- summary under Subsection 80(1) Summary Under Tax Topics- Income Tax Act- Section 80- Subsection 80(1) Where receivables are transferred to the debtor corporation in consideration for treasury shares, s. 80 applies if the fair market value of the shares is less than the principal amount of the debt. ...
Technical Interpretation - External summary
3 December 1990 T.I. (Tax Window, Prelim. No. 2, p. 11, ¶1062) -- summary under Subsection 80(5)
No. 2, p. 11, ¶1062)-- summary under Subsection 80(5) Summary Under Tax Topics- Income Tax Act- Section 80- Subsection 80(5) Where receivables are transferred to the debtor corporation in consideration for treasury shares, s. 80 applies if the fair market value of the shares is less than the principal amount of the debt. ...
Technical Interpretation - External summary
7 January 2004 External T.I. 2003-001953 -- summary under Subsection 108(7)
7 January 2004 External T.I. 2003-001953-- summary under Subsection 108(7) Summary Under Tax Topics- Income Tax Act- 101-110- Section 108- Subsection 108(7) If a trust is established by contributions from two or more unrelated persons and those unrelated persons are beneficiaries of the trust, their respective interests in the trust would be considered to have been acquired for consideration. ...
Ruling summary
2000 Ruling 1999-001074 -- summary under Paragraph 85(1)(b)
2000 Ruling 1999-001074-- summary under Paragraph 85(1)(b) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1)- Paragraph 85(1)(b) S.85(1)(b) would not apply where the portion of liabilities assumed by the transferee that were in excess of the cost amount of the transferred property were so assumed in consideration for a cash payment. ...