Search - consideration
Results 3531 - 3540 of 8027 for consideration
Miscellaneous severed letter
3 August 1988 Income Tax Severed Letter RCT 5-5889
Accordingly, it is proposed that the capital of Opco be reorganized as follows: 1) All of the shareholders of Opco will exchange their common shares for special shares having paid-up capital equal to the paid-up capital of the common shares, and a redemption value and fair market value equal to the fair market value of the common shares at that time. 2) The Sons will subscribe for new common shares for nominal consideration. ...
Miscellaneous severed letter
23 December 1986 Income Tax Severed Letter RCT 5-2174 F
The consideration received on the transfer will be debt with a fair market value of $150,000 and common shares having a nominal paid-up capital. 7. ...
Miscellaneous severed letter
24 June 1981 Income Tax Severed Letter RT 247-045
They will receive common shares in H Ltd. as sole consideration on the transfer. ...
Miscellaneous severed letter
25 September 1989 Income Tax Severed Letter HBW 2044-2-9
(c) One of the conditions for consideration for an assignment is that the employee has demonstrated a potential for advancement to senior positions. ...
Miscellaneous severed letter
18 October 1989 Income Tax Severed Letter RCT 5-8074
Should you wish to request an advance income tax ruling in respect of a particular proposed transaction, we would be pleased to give further consideration to such foreign exchange hedging arrangements. ...
Miscellaneous severed letter
16 January 1987 Income Tax Severed Letter RCT 5-2286 F
.'s shares by OPCO, which you indicate in your letter to be your view, the provisions of subsection 55(2) of the Act clearly state that income earned or realized by OPCO after that commencement date is not to be taken into consideration in determining the relevant income earned or realized by any corporation after 1971 for the purposes of subsection 55(2) of the Act. ...
Miscellaneous severed letter
23 April 1981 Income Tax Severed Letter RCT 85-339
You describe a situation where a partnership between an individual and a holding company intends to sell in an arm's length transaction its only significant asset, a rental property, for a consideration consisting of the assumption of the existing mortgage by the purchaser and the issue of a second mortgage. ...
Miscellaneous severed letter
31 May 1984 Income Tax Severed Letter RCT 5-6249 F
T acquired the preferred shares of Company X as consideration for the disposition of an asset the fair market value of which at the time of the disposition was $100,000 less than the adjusted cost base ("acb") to T of the asset. 3. ...
Miscellaneous severed letter
12 February 1980 Income Tax Severed Letter RCT 5-789
Workload constraints prevented us from giving full consideration to your query until this time. ...
Miscellaneous severed letter
17 October 1988 Income Tax Severed Letter 5-6339 - Application of section 183.1 to a particular situation
As consideration for the transfer Y would receive a note equal to his ACB of the transferred shares and shares of Holdco having a value equal to the difference between the FMV and X's ACB of the transferred shares. 6. ...