Search - consideration

Results 3251 - 3260 of 8025 for consideration
Technical Interpretation - External

2 May 1994 External T.I. 9332595 - PRESCRIBED SHARES

When the lawyer completed the transaction he issued, in error, an existing class of preference shares ("old" preference shares), as consideration for the re-purchase of common shares. ...
Ministerial Letter

2 March 1994 Ministerial Letter 930668A - INDIAN TRUSTS

Following a thorough analysis of the Williams case and due consideration of extensive input from the Indian community, the Department has developed four guidelines dealing with the taxation of employment income of Indians. ...
Technical Interpretation - External

26 May 1994 External T.I. 9409635 - CASHING OUT A HEALTH CARE SPENDING ACCOUNT

As stated in paragraph 3 of Interpretation Bulletin IT-339R2 "Meaning of "Private Health Services Plan"", a plan of insurance must contain the following basic elements of insurance: a)an undertaking by one person, b)to indemnify another person, c)for agreed consideration, d)from the loss or liability in respect of an event, e)the happening of which is uncertain. ...
Technical Interpretation - External

31 May 1994 External T.I. 9411795 - INTERSPOUSE TRANSFERS AND RRSP'S

XXXXXXXXXX 941179 Attention: XXXXXXXXXX May 31, 1994 Dear Sirs: Re: Registered Retirement Savings Plan (RRSP) This is in reply to your letter of April 15, 1994, in which you ask whether section 74.1 of the Income Tax Act (unless as otherwise stated all references to this statute are to the Income Tax Act S.C. 1970-71-72, c. 63 as amended, consolidated to June 10, 1993- the "Act") would apply where: an individual transfers cash to a spouse for no consideration, the spouse contributes the cash to an RRSP of which the spouse is the annuitant, the spouse claims the contribution deduction pursuant to 146(5) of the Act, and some time later the spouse withdraws the money and that amount is included in the spouse's income pursuant to subsection 146(8) and paragraph 56(1)(h) of the Act. ...
Miscellaneous severed letter

8 December 1993 Income Tax Severed Letter 9333680 - Option Agreements—Non-arm's length Situations

Subsection 49(3) provides that in computing the vendor's proceeds of disposition of the property, there shall be included the consideration received for the option. ...
Technical Interpretation - External

4 July 1994 External T.I. 9414445 - INVESTMENT COUNSEL FEES

In determining whether a fee is reasonable, the amount of time spent and the type of work done by the person providing the advice or service will be taken into consideration. ...
Ministerial Letter

13 June 1994 Ministerial Letter 9413888 - EMPLOYEE/EMPLOYER STATUS

The Department takes many factors into consideration in establishing whether an individual is an employee or self-employed. ...
Technical Interpretation - Internal

24 August 1994 Internal T.I. 9420517 - INTEREST DEDUCTIBILITY

The assets of the proprietorship were transferred to the corporation for consideration that consisted of common shares and a note payable to the shareholder. ...
Technical Interpretation - External

2 February 1994 External T.I. 9402155 - SUCCESSOR RULE - AMALGAMATION OF TWO EXEMPT CORPORATIONS

We will be forwarding this matter to the attention of the Department of Finance for their consideration. ...
Technical Interpretation - Internal

20 April 1994 Internal T.I. 9409740 - WITHHOLDING TAX - SOFTWARE MAINTENANCE FEES

Consideration would have to be given to whether the up-front fee was reasonable and whether a portion of the annual maintenance fee could be considered to be for use of the custom computer software. ...

Pages