Search - consideration

You presented the following situations to us for our consideration: Corporation A, resident in Canada, owns all the shares of Corporation X, a foreign affiliate. ...

We do not have sufficient information concerning the staff retirement funds or the circumstances under consideration by you in connection therewith to comment definitively as to the proper tax treatment thereof. ...

Although an allowance based on the 31 cents/25 cents per kilometre rate specified in draft Regulation 7305 may be considered reasonable in many situations, it is our view that the actual costs incurred by an employee should be taken into consideration in determining what would be a reasonable rate for the allowance. ...

The consideration received by the parent might include a preferred share retractable at the option of the parent for an amount equal to the fair market value ("FMV") of the Opco shares transferred. ...

Whether or not a particular legal defeasance is a legal defeasance which effects novation can only be determined following consideration of all of the terms and conditions pertaining to the particular defeasance. ...

Specifically, you have referred the following example for our consideration: A corporation, whose fiscal year end is September 30, has been carrying on business since before January 1, 1972. ...

Briefly, the proposal under consideration concerns the addition of a rider to a group accident and sickness policy which is part of a wage loss replacement plan pursuant to an employer-employee agreement. ...

The dividend payment would be taken in to consideration in any future calculation of safe income. ...

The comments expressed in this letter are of a purely general nature and do not take into account considerations that might arise in the context of a specific transaction. ...

The opinions expressed in this letter are of a purely general nature and do not take into account considerations that might arise in the context of a specific transaction. ...