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Results 3541 - 3550 of 8030 for consideration
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. ...
Miscellaneous severed letter
22 June 1989 Income Tax Severed Letter 5-8123 - Sale of accumulated income in registered education savings plans
We would however accept a clause in a contract that permits the subscriber to assign, for valuable consideration, his obligations under the contract to another person. ...
Miscellaneous severed letter
15 April 1992 Income Tax Severed Letter 9205277 - Transfer of retiring allowance to registered retirement savings plan
The number of years with the previous employer that would count for the purposes of clause 60(j.1)(ii)(A) of the Act would be those years of service with the previous employer that were taken into consideration in determining the amount of the pension benefits. ...
Miscellaneous severed letter
13 December 1989 Income Tax Severed Letter 5-8765 - Nature of a loss incurred on the disposition of a mortgage receivable
As partial consideration for the sale, Opco took back a mortgage receivable from the purchaser ("Purchaseco"). 4. ...
Miscellaneous severed letter
17 February 1992 Income Tax Severed Letter 9201575 - Dental plan — private health services plan
In order for a particular DRDP to qualify as a PHSP, as defined, the plan implemented by an employer on behalf of its employees must be in the nature of insurance and must contain the following elements as set out in paragraph 3 of IT-339R2: (i) an undertaking of one person, (ii) to indemnify another person, (iii) for an agreed consideration, (iv) from a loss or liability in respect of an event, (v) the happening of which is uncertain. ...
Miscellaneous severed letter
27 January 1992 Income Tax Severed Letter 9200300 - Auto benefit for dog handler
This position is not altered by various other considerations such as the fact that an employer may require an employee to return to the work site after hours. ...
Miscellaneous severed letter
22 August 1989 Income Tax Severed Letter 5-7720 - Retirement compensation arrangements
The comments in this letter are purely of a general nature and do not take into account considerations that might arise in the context of a specific transaction or event. ...
Miscellaneous severed letter
2 April 1990 Income Tax Severed Letter 0-0350 - Proposed Part 1.3 of the Income Tax Act—tax on large corporations resource industry issues
Meeting with Finance In response to numerous queries received from Revenue Canada concerning the proposed Part 1.3 tax, Finance agreed to attend a meeting with us to discuss their intent and policy considerations inherent in the drafting of the Part 1.3 legislation. ...
Miscellaneous severed letter
7 September 1989 Income Tax Severed Letter 5-8427 - Interpretation of the types of expenses that are included in the definition of Canadian exploration expense
You have offered two interpretations of CEE for our consideration: 1. ...